SUMMARY: The Securities and Exchange Commission (the “Commission”) is proposing

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SECURITIES AND EXCHANGE COMMISSION 

17 CFR Parts 270 and 274 

[Release No. IC-35962; File No. S7-2026-05] 

RIN 3235-AN44 

Form N-PORT Reporting 

AGENCY: Securities and Exchange Commission.  

ACTION: Proposed rule. 

SUMMARY: The Securities and Exchange Commission (the “Commission”) is proposing 

amendments to reporting requirements on Form N-PORT that apply to certain registered 

investment companies, including registered open-end funds, registered closed-end funds, and 

exchange-traded funds organized as unit investment trusts. The proposed amendments would 

modify provisions adopted in 2024 to provide these funds with an additional fifteen days to file 

monthly reports of portfolio-related information on Form N-PORT and would restore the 

quarterly publication frequency that had been in place for over two decades. The Commission is 

proposing these amendments in light of feedback from market participants and other 

developments. The Commission is also proposing to streamline or remove certain items and sub-

items, reducing reporting burdens in ways that would not significantly affect the Commission’s 

uses of the data and are not expected to significantly affect the public’s ability to assess relevant 

information about a fund. Finally, the Commission is proposing to adjust how funds with share 

classes that operate as exchange-traded funds report certain information to improve information 

about this fund structure and to require information about funds’ ticker symbols, as well as 

certain class-level identifiers, as applicable, to facilitate efficient use of the reported information. 

DATES: Comments should be submitted on or before April 24, 2026. 

Conformed to Federal Register version



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ADDRESSES: Comments may be submitted by any of the following methods: 

Electronic Comments: 

• Use the Commission’s internet comment form (https://www.sec.gov/comments/s7-2026-

05/form-n-port-reporting); or  

• Send an email to [email protected]. Please include File Number S7-2026-05 on 

the subject line. 

Paper Comments: 

• Send paper comments to Secretary, Securities and Exchange Commission, 100 F Street 

NE, Washington, DC 20549-1090. 

All submissions should refer to File Number S7-2026-05. This file number should be 

included on the subject line if email is used. To help the Commission process and review your 

comments more efficiently, please use only one method of submission. The Commission will 

post all comments on the Commission’s website (https://www.sec.gov/comments/s7-2026-

05/form-n-port-reporting). Do not include personal identifiable information in submissions; you 

should submit only information that you wish to make available publicly. We may redact in part 

or withhold entirely from publication submitted material that is obscene or subject to copyright 

protection. 

Studies, memoranda, or other substantive items may be added by the Commission or staff 

to the comment file during this rulemaking. A notification of the inclusion in the comment file of 

any such materials will be made available on the Commission’s website. To ensure direct 

electronic receipt of such notifications, sign up through the “Stay Connected” option at 

www.sec.gov to receive notifications by email. 

https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting
https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting
https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting
https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting


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A summary of the proposal of not more than 100 words is posted on the Commission’s 

website (https://www.sec.gov/rules-regulations/2026/02/s7-2026-05). 

FOR FURTHER INFORMATION CONTACT: Susan Ali, Counsel; Angela Mokodean, 

Senior Special Counsel; or Brian M. Johnson, Assistant Director at (202) 551-6792, Investment 

Company Regulation Office, Division of Investment Management, Securities and Exchange 

Commission, 100 F Street NE, Washington, DC 20549-8549. 

SUPPLEMENTARY INFORMATION: The Commission is proposing amendments to 17 

CFR 270.30b1-9 (“rule 30b1-9”), 17 CFR 274.150, and Form N-PORT [referenced in 17 CFR 

274.150] under the Investment Company Act of 1940 (the “Act”). 

TABLE OF CONTENTS 

I. Introduction ................................................................................................................... 4 
A. Developments after Adoption of the 2024 Amendments ........................................... 6 
B. Overview of Proposed Amendments .......................................................................... 8 

II. Discussion..................................................................................................................... 11 
A. Filing Timeframe ...................................................................................................... 11 
B. Publication Frequency .............................................................................................. 25 
C. Other Proposed Amendments to Form N-PORT ...................................................... 36 
D. Proposed Transition Period ....................................................................................... 60 

III. Economic Analysis ...................................................................................................... 63 
A. Introduction ............................................................................................................... 63 
B. Baseline ..................................................................................................................... 65 

1. Regulatory Baseline .......................................................................................... 66 
2. Affected Entities ............................................................................................... 68 
3. Economic Literature on the Disclosure of Registered Fund Portfolio Holdings

 72 
C. Benefits and Costs of the Amendments .................................................................... 74 

1. Filing Timeframe .............................................................................................. 74 
2. Publication Frequency ...................................................................................... 76 
3. Other Proposed Amendments to Form N-PORT .............................................. 79 
4. Monetized Benefits and Costs .......................................................................... 84 

https://www.sec.gov/rules-regulations/2026/02/s7-2026-05


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5. Present Values and Annualized Values of Monetized Benefits and Costs ....... 86 
D. Effects on Efficiency, Competition, and Capital Formation ..................................... 89 

1. Efficiency .......................................................................................................... 89 
2. Competition....................................................................................................... 91 
3. Capital Formation ............................................................................................. 91 

E. Reasonable Alternatives............................................................................................ 92 
1. Filing Timeframe .............................................................................................. 92 
2. Publication of Registered Fund Holdings ......................................................... 93 

IV. Paperwork Reduction Act .......................................................................................... 94 
A. Introduction ............................................................................................................... 94 
B. Form N-PORT .......................................................................................................... 95 
C. Request for Comment ............................................................................................... 99 

V. Initial Regulatory Flexibility Analysis .................................................................... 100 
A. Reasons for and Objectives of Proposed Actions ................................................... 101 
B. Legal Basis .............................................................................................................. 101 
C. Small Entities Subject to the Amendments ............................................................. 101 
D. Projected Reporting, Recordkeeping, and Other Compliance Requirements ......... 102 
E. Duplicative, Overlapping, or Conflicting Federal Rules ........................................ 103 
F. Significant Alternatives .......................................................................................... 103 
G. General Request for Comment................................................................................ 106 

VI. Consideration of Impact on the Economy .............................................................. 106 
VII. Other Matters ........................................................................................................ 107 
Statutory Authority ............................................................................................................ 107 

 

I. Introduction  

 On August 28, 2024, the Commission adopted amendments to Form N-PORT to require 

more frequent reporting of monthly portfolio holdings and related information to the 

Commission and the public, and to modify certain reporting requirements relating to entity 



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identifiers (the “2024 amendments”).1 Many registered investment companies are required to 

report on Form N-PORT, including registered open-end funds, registered closed-end funds, and 

exchange-traded funds (“ETFs”) organized as unit investment trusts, but excluding money 

market funds and small business investment companies (hereinafter, registered investment 

companies that are required to report on Form N-PORT are referred to as “registered funds”). 

Reports on Form N-PORT provide monthly information about a registered fund’s complete 

portfolio holdings, as well as related information to help assess a fund’s risks, including 

investment risk (e.g., interest rate risk, credit risk, and volatility risk), liquidity risk, counterparty 

risk, and leverage. These reports are an important source of information for the Commission and 

its staff in carrying out regulatory responsibilities related to registered funds and the broader 

asset management industry. Overall, the 2024 amendments were intended to provide the 

Commission and the public with timelier information about funds’ portfolio investments, 

enabling more comprehensive oversight of an ever-evolving registered fund industry by the 

Commission and providing investors with information to make more informed investment 

decisions. 

As discussed in more detail below, several developments occurred following the adoption 

of the 2024 amendments. As a result, the Commission has delayed the effective and compliance 

dates of the 2024 amendments and reviewed those amendments and their possible effects, as set 

forth in this release. In connection with that review, we are proposing to provide funds with 

fifteen additional days to file monthly reports with the Commission. This additional time is 

 
1  Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management 

Programs, Investment Company Act Release No. 35308 (Aug. 28, 2024) [89 FR 73764 (Sept. 11, 2024)] 
(“2024 Adopting Release”), https://www.sec.gov/files/rules/final/2024/ic-35308.pdf. The Commission also 
adopted amendments to Form N-CEN and provided guidance on liquidity risk management program 
requirements for open-end funds. Those aspects of the 2024 Adopting Release are not affected by this 
proposal. 



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designed to reduce the risk of errors in the reported information and reduce reporting burdens 

while continuing to recognize that Form N-PORT information is more valuable to the 

Commission and staff when it reflects more current portfolio holdings and related information. 

Additionally, to reduce the risk associated with the 2024 amendments that external parties may 

use more frequent disclosures of a registered fund’s portfolio holdings to infer the fund’s 

proprietary investment strategy or trading intentions and use that information in ways that 

increase costs for the fund and its shareholders, and in light of advancements in technology, we 

are proposing to revert to providing the public with access to quarterly snapshots of portfolio 

information on Form N-PORT, consistent with requirements for the past two decades prior to the 

adoption of the 2024 amendments.2  

The Commission is also proposing to remove or streamline certain items and sub-items of 

the form to refine the information that is collected without significantly affecting the utility of 

the reported information. In addition, we are proposing to require registered funds with share 

classes that operate as exchange-traded funds (“ETF share classes”) to report certain information 

on the form to improve the Commission’s and the public’s understanding of the size and flows of 

this type of fund structure. Finally, we are proposing to require registered funds to report certain 

additional identifying information, such as ticker symbols, to help data users use the reported 

information more efficiently. 

A. Developments after Adoption of the 2024 Amendments 

Following adoption of the 2024 amendments, several developments caused the 

Commission to delay the effective and compliance dates of the 2024 amendments and review 

 
2  See Shareholder Reports and Quarterly Portfolio Disclosure of Registered Investment Companies, 

Investment Company Act Release No. 26372 (Feb. 27, 2004) [69 FR 11244 (Mar. 9, 2004)] (“Shareholder 
Reports and Quarterly Portfolio Disclosure Release”). 



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their potential effects.3 In October 2024, petitioner Registered Funds Association filed a petition 

in the Fifth Circuit Court of Appeals seeking review of the 2024 amendments.4 Although the 

petitioner challenged the Form N-PORT amendments as a whole, it emphasized concerns related 

to more frequent publication of registered funds’ portfolio holdings. These proceedings are 

currently stayed while the Commission reviews the 2024 amendments and considers potential 

changes.5  

 Additionally, on January 20, 2025, President Donald J. Trump signed a Presidential 

Memorandum directing agencies to consider postponing the effective date for any rules that had 

been issued but had not yet taken effect for the purpose of reviewing any questions of fact, law, 

and policy that the rules may raise.6 The Presidential Memorandum further states that, for those 

rules that raise substantial questions of fact, law, or policy, agencies should take further 

appropriate action. Moreover, the President subsequently issued additional Executive Orders 

expressing a policy goal of reducing regulatory burdens.7 At the time of the signing of the 

Presidential Memorandum, the 2024 amendments, while issued, had not yet taken effect. As a 

 
3  Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management 

Programs; Delay of Effective and Compliance Dates, Investment Company Act Release No. 35538 (Apr. 
16, 2025) [90 FR 16812 (Apr. 22, 2025)] (“2025 Delay Release”), 
https://www.sec.gov/files/rules/final/2025/ic-35538.pdf. Specifically, the Commission delayed the effective 
date for the Form N-PORT amendments from Nov. 17, 2025, to Nov. 17, 2027, and delayed the compliance 
date from Nov. 17, 2025, to Nov. 17, 2027, for larger entities and from May 18, 2026, to May 18, 2028, for 
smaller entities. 

4  Registered Funds Association v. SEC, No. 24-60550 (5th Cir. 2024). 
5  See ECF No. 50-2, Registered Funds Association v. SEC, No. 24-60550 (5th Cir. Feb. 11, 2025). 
6  Regulatory Freeze Pending Review (Jan. 20, 2025) [90 FR 8249 (Jan. 28, 2025)], available at 

https://www.whitehouse.gov/presidential-actions/2025/01/regulatory-freeze-pending-review/ (“Presidential 
Memorandum”). The Presidential Memorandum directed agencies to consider postponing the effective date 
of any such rules for 60 days and, as appropriate and consistent with applicable law, and where necessary 
to continue to review the questions of fact, law, and policy, consider further delaying, or publishing for 
notice and comment proposed rules further delaying such rules, beyond the 60-day period. 

7  See, e.g., Unleashing Prosperity Through Deregulation (Jan. 31, 2025) [90 FR 9065 (Feb. 6, 2025)], 
available at https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-prosperity-through-
deregulation/. 



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result, the Commission initiated a review of the 2024 amendments to consider questions of fact, 

law, or policy associated with the amendments. While performing the review, we also considered 

other aspects of Form N-PORT and the overall effectiveness and usability of information 

reported on the form. 

 Since the adoption of the 2024 amendments, the Commission also has received additional 

feedback on the amendments, including through staff outreach, to inform our review of the 

amendments. Through letters and meetings, registered fund industry members have further 

highlighted and provided additional information about the potential negative impacts of the 

amendments as industry members began to focus on implementation. For example, industry 

members have indicated that the 30-day reporting timeframe requires registered funds to gather 

data more quickly than current operational processes contemplate and to accelerate internal 

review and signoff procedures, which we understand is particularly difficult for certain funds 

with more complex strategies, and increases the overall risk of errors and resubmissions. 

Additionally, a letter from a registered fund industry group suggested that the amendments 

would also harm registered fund shareholders and curb fund innovation and suggested that the 

Commission amend its approach.8  

B. Overview of Proposed Amendments 

 As part of the Commission’s review of the Form N-PORT amendments, we have 

considered available information, including additional information and evolving dynamics 

following the adoption of the amendments, and accordingly have reassessed the benefits and 

costs of the amendments. As a result of this review, we are proposing to extend the filing 

 
8  See Letter from Investment Company Institute (Feb. 26, 2025) (“ICI Letter”), available at 

https://www.ici.org/system/files/2025-02/25-cl-form%20nport-amendments.pdf. 



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deadline from 30 to 45 days after month end and are proposing to publish reports for only the 

third month of a registered fund’s fiscal quarter 60 days after month end. Table 1 below displays 

the key elements of the Form N-PORT requirements that were revised as a part of the 2024 

amendments and compares the previous Form N-PORT requirements, the 2024 amendments, and 

the current proposal.9    

Table 1. Comparison of Form N-PORT Requirements Prior to 2024 Amendments, the 

2024 Amendments, and the Proposed Amendments 

 Requirements Prior 
to 2024 

Amendments1 

2024 Amendments Proposed 
Amendments 

Filing Timeframe Reports for each 
month in a registered 
fund’s fiscal quarter 
must be filed no later 
than 60 days after the 
end of the relevant 
fiscal quarter 

Reports for each 
month must be filed 
no later than 30 days 
after the end of the 
relevant month 

Reports for each 
month must be filed 
no later than 45 days 
after the end of the 
relevant month 

Publication 
Frequency 

Information reported 
for the third month of 
a registered fund’s 
fiscal quarter will be 
made public upon 
filing (i.e., no later 
than 60 days after 
fiscal quarter end) 

Information reported 
for each month will 
be made public 60 
days after month end 

Information reported 
for the third month of 
a registered fund’s 
fiscal quarter will be 
made public 60 days 
after fiscal quarter 
end 

Recordkeeping  No later than 30 days 
after the end of each 
month, a registered 
fund must maintain in 
its records the 
information that 
Form N-PORT 
requires  

N/A N/A 

Entity Identifiers Certain items require 
reporting of a legal 
entity identifier 

Provides separate 
fields for reporting 

No change to 2024 
amendments. 

 
9  For a table displaying the key proposed changes to the information registered funds are required to report 

on Form N-PORT, see infra section II.C, Table 2. 



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(“LEI”), if any, of a 
counterparty or 
issuer. If an LEI has 
not been assigned, 
registered funds 
instead provide in the 
LEI field an RSSD 
ID, if any, assigned 
by the National 
Information Center of 
the Board of 
Governors of the 
Federal Reserve 
System. 

LEI or RSSD ID, if 
any. 

Notes: 
 
1. The requirements described in this column are currently in effect and reflect the approach that registered funds 
currently are required to follow, as the effective date of the 2024 amendments has been delayed until November 
17, 2027. 

 

The proposed amendments would continue to provide the Commission with reasonably 

timely data while also reducing operational burdens and the risk of errors. In addition, compared 

to the 2024 amendments, the proposed quarterly publication schedule is designed to reduce the 

risk of external parties inferring a registered fund’s proprietary trading strategy or trading 

intentions from Form N-PORT reports and acting on that information in a way that is harmful to 

the fund. We are soliciting public comment on whether the proposed changes strike an 

appropriate balance between the benefits of portfolio-related information for the Commission 

and the public and the burdens to registered funds of reporting such information. 

Separate from the proposed changes to the filing timeframe and publication frequency of 

Form N-PORT reports, we are proposing to modify certain information collected on portfolio 

level risk metrics and returns to narrow their scope, and proposing to eliminate certain 

information collected on non-derivatives instruments’ payoff profiles, convertible bonds, and the 

reason a single holding has multiple liquidity classifications. In addition, we are proposing to 



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remove the reporting requirements added to Form N-PORT when the Commission adopted 

amendments to rule 35d-1 under the Act (the “names rule”).10 The proposed amendments to 

streamline or remove reporting requirements would not significantly affect the Commission’s 

uses of the data and are not expected to significantly affect the public’s ability to assess relevant 

information about a registered fund, but would reduce the reporting burden for these funds.  

Finally, we are proposing to require certain additional information. We propose to require 

a registered fund with an ETF share class to report information on the ETF class’s net assets and 

shareholder flows. These amendments are designed to provide the Commission and investors 

with information to better understand the size and flows of this type of fund structure. We also 

propose to require registered funds to provide information about their ticker symbols, as well as 

certain class-level identifiers, as applicable. These amendments are designed to help data users 

more efficiently use other information that is reported on the form.   

II. Discussion 

A. Filing Timeframe  

 We are proposing to amend rule 30b1-9 and Form N-PORT to require registered funds to 

file Form N-PORT reports within 45 days after the end of the month to which they relate.11 

Specifically, rather than filing monthly reports with the Commission within 60 days after the end 

of each fiscal quarter consistent with the prior rule or within 30 days after the end of each 

calendar month as required under the 2024 amendments, we are proposing to require registered 

funds file reports on a monthly basis within 45 days after the end of the month to which they 

 
10  See Investment Company Names, Investment Company Act Release No. 35000 (Sept. 20, 2023) [88 FR 

70436 (Oct. 11, 2023)], Investment Company Names; Correction, Investment Company Act Release No. 
35000A (Oct. 24, 2023) [88 FR 73755 (Oct. 27, 2023)] (“Names Rule Adopting Release”). Funds have not 
begun to comply with the names rule-related reporting requirements on Form N-PORT. 

11  See General Instruction A of proposed Form N-PORT; proposed rule 30b1-9. We are also proposing 
conforming amendments to 17 CFR 274.150. 



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relate. These proposed changes are intended to better balance the need for the Commission to 

receive timely data against burdens to registered funds relative to the 2024 amendments. 

Specifically, the proposed approach would provide registered funds with an additional 15 days to 

gather, verify, and file information relative to the 30-day filing requirement in the 2024 

amendments. 

 As a general matter, the Commission and its staff use information in Form N-PORT 

reports to carry out regulatory responsibilities related to registered funds, and investors benefit 

indirectly from the Commission’s use of Form N-PORT information. For instance, the 

Commission and staff use Form N-PORT information for purposes of examination, enforcement, 

and monitoring of registered funds, including assessing regulatory compliance, identifying funds 

for examination, and risk monitoring. Form N-PORT reports also provide the Commission 

information that is useful to understand trends in the registered fund industry and to inform and 

formulate regulatory policy. Further, the Commission uses Form N-PORT information in 

connection with its review of fund registration statements and disclosures (e.g., by considering a 

fund’s portfolio holdings in relation to its disclosures). Finally, in the case of market events, the 

Commission uses Form N-PORT information to help assess the breadth and magnitude of the 

potential impacts of such events (e.g., to analyze registered funds’ potential exposures to issuers 

or asset classes that are under stress due to market events). 

 When the Commission adopted the 2024 requirement to file monthly reports within 30 

days of month end, it acknowledged tradeoffs in how frequently and quickly registered funds 

must file Form N-PORT information. While more frequent and timely filings enhance the 

Commission staff’s ability to oversee and monitor registered funds’ activities (as the information 

is more likely to reflect reasonably current portfolio information), it also increases costs, the 



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potential for errors in filed information and, for funds that do not voluntarily publicly disclose 

their portfolio holdings on a more frequent basis, increases the sensitivity of the filed information 

and the associated risk of misappropriation in the event of a system breach.12 As part of our 

review, we reconsidered these tradeoffs, accounting for additional information from registered 

funds’ preliminary implementation efforts, comments submitted in connection with the 2024 

amendments, and the Commission’s need for and uses of information contained in Form N-

PORT reports. Information gathered and reassessed during the review informed the development 

of the proposed amendments.  

Since the adoption of the 2024 amendments and as registered fund industry members 

further considered implementation, we have received additional information from industry 

members about the burdens of filing Form N-PORT reports within 30 days of month end through 

staff outreach to registered funds and fund administrators, as well as a letter from a group 

representing the registered fund industry.13 During staff outreach, industry members raised 

concerns about filing complete and accurate Form N-PORT reports within 30 days. Industry 

members discussed certain dependencies that could impact the ability to have Form N-PORT 

reports complete and error-free within this timeframe. For example, registered funds may rely on 

third parties for certain data related to liquidity, derivatives, or risk metrics, and in turn, those 

third parties may have their own data dependencies. In some cases, particularly for funds with 

complex strategies, the third parties may not provide data until shortly before the 30-day filing 

deadline. These delays result in limited time for internal reviews and signoffs on the data, 

particularly considering that some time is also needed to complete the filing process, and 

 
12  See 2024 Adopting Release, supra note 1, at section II.A.1. 
13  See ICI Letter. 



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increase the potential for errors in the report. Specifically, for fund complexes or fund 

administrators with a large volume of reports to file, it may take multiple days to handle the 

filing process.  

Due to the time required to receive, review, and file Form N-PORT information, industry 

members suggested that a 30-day filing deadline would increase the potential for errors and 

resubmissions and would cause some industry members to hire additional personnel to manage 

the condensed timeframe and the larger volume and greater frequency of filings. Industry 

members suggested that there would be a larger volume of filings as a result of the 2024 

amendments because they assumed that: (1) errors and resubmissions would increase; and (2) the 

Regulation S-X compliant presentation of holdings for the first and third fiscal quarter under Part 

F of Form N-PORT would be filed separately 60 days after quarter end. 

Industry members also discussed challenges in filing Form N-PORT reports within 30 

days of month end for closed-end funds that calculate their net asset values on a monthly basis 

and invest in private funds or other hard to value assets. Such closed-end funds have experienced 

growth in recent years and may continue to grow in number and size. Industry members 

suggested that, for some of these funds, there may not be an initial net asset value calculation 

until three weeks or later after month end. Industry members expressed concern that these funds 

may have to file reports that are not entirely accurate and then make an amended filing for 

accuracy.  

In light of concerns about the effects of a 30-day filing requirement, some registered fund 

industry members suggested that we further amend Form N-PORT to provide additional time, 



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such as 45 days, for funds to file monthly reports.14 In outreach, industry members suggested that 

a 45-day filing timeline, although still involving some costs, would reduce the risk of errors and 

reduce the need to hire additional personnel by providing additional time to gather, review, and 

file the required information. Some industry members suggested that a longer filing timeline, 

such as 60 days after month end or 60 days after quarter end, would further reduce burdens. 

In addition to the information obtained through outreach, we considered the concerns 

commenters raised in conjunction with the 2024 amendments.15 Commenters raised concerns 

that requiring monthly reporting within 30 days of month end would overburden registered 

funds, including fund internal systems and processes, as well as service providers. Commenters 

also discussed the overlap in teams that prepare, review, and file Form N-PORT reports with 

those that are involved with other required filings, suggesting that a 30-day filing timeline for 

Form N-PORT would cause strains on those teams. A few commenters further suggested that 

these strains would be pronounced for the months following the end of the reporting period when 

the annual and semiannual reports are due. Some commenters expressed concern about data 

security and the risk that confidential and proprietary registered fund information could be 

misappropriated as a result of unauthorized access. In general, these various concerns were 

consistent with the information we received through outreach. 

We also considered the Commission’s and staff’s use of Form N-PORT information and 

the potential effects of receiving Form N-PORT information later than 30 days after month end. 

As discussed in the 2024 Adopting Release, the quarterly filing requirement has limited the 

Commission’s ability to develop a timely and more complete understanding of the market. In 

 
14  See ICI Letter (stating that the Commission should extend the filing deadline to “at least 45 days” to avoid 

increased errors and resubmissions). 
15  See 2024 Adopting Release, supra note 1, at section II.A.1. 



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addition, although the Commission has had the ability to request registered fund records of Form 

N-PORT information within 30 days of month end, this has not been an effective substitute for 

receiving more timely information through filings.16 The Commission and its staff use Form N-

PORT information to, among other things, monitor industry trends, identify risks, inform policy 

and rulemaking, and assist Commission staff in examination and enforcement efforts. Timely 

Form N-PORT data improves the Commission’s ability to (1) conduct more targeted and timely 

monitoring efforts; (2) analyze risks and trends more accurately; and (3) better assess the breadth 

and magnitude of potential market events and stress affecting particular issuers, asset classes, 

counterparties, or market participants. The Commission’s ability to perform these functions 

effectively and efficiently benefits investors and the markets, including for example during times 

of market stresses and events.  

 As a general matter, the Commission adopted the 30-day filing requirement because (1) 

given that registered funds were already required to maintain records of Form N-PORT 

information within the 30-day period in which filings would be due, the Commission did not 

expect the burden to be significant;17 (2) the Commission historically has viewed access to Form 

N-PORT information within 30 days of month end as important to furthering our mission to 

protect investors;18 and (3) delays in receipt of Form N-PORT information reduce the utility of 

the information for the Commission.19 The additional information we have received from market 

participants following adoption of the 2024 amendments as funds further considered 

implementation suggests, however, that the burdens of filing Form N-PORT reports within 30 

 
16  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.57. 
17  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.75. 
18  See id. at paragraph accompanying n.60. 
19  See id. at paragraph accompanying n.61. 



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days of month end would be greater than the Commission anticipated due to the time it takes to 

compile, review, and file certain data, particularly for registered funds with complex strategies or 

certain types of closed-end funds, and the risk of errors and resubmissions if processes must be 

condensed. Providing an additional 15 days to file Form N-PORT reports should mitigate these 

burdens, but generally would not decrease the utility of the information for the Commission 

significantly or the indirect benefits to investors associated with the Commission’s use of Form 

N-PORT information. As a result, we are proposing to extend the filing timeframe to provide 

registered funds with 45 days after month end to file Form N-PORT reports.  

Providing 45 days for registered funds to file Form N-PORT reports would reduce 

burdens for the funds and their service providers, as they would have additional time to gather 

information, verify its accuracy, and prepare and make the filings. This additional time should 

also mitigate the effect that a monthly filing requirement would have on the workload of 

personnel or service providers that prepare and file Form N-PORT reports.20 Moreover, the 

additional time should reduce the potential for errors in Form N-PORT filings and reduce 

potential resubmissions. By reducing costs associated with the 2024 amendments, the proposal 

should also mitigate the extent to which costs associated with monthly reporting requirements 

are passed on to registered fund shareholders. We also recognize that the additional time to file 

would reduce the sensitivity of the information filed with the Commission, which should reduce 

the concern that some industry members have raised about data security and the risk that 

 
20  In 2016, when the Commission first adopted a requirement to file Form N-PORT reports within 30 days of 

month end, the Commission suggested that lag times of more than 30 days would make monthly reporting 
impractical, as reports would overlap with preparation time. See Investment Company Reporting 
Modernization, Investment Company Act Release No. 32314 (Oct. 13, 2016) [81 FR 81870 (Nov. 18, 
2016)] (“Reporting Modernization Adopting Release”), at nn.462-464 and accompanying text. Commenters 
on the 2024 rulemaking did not raise this overlap as a concern, although we understand that registered 
funds and their service providers would be the ones to bear this type of effect most directly. Given that the 
directly affected parties have not raised the overlap as a concern, we do not at this time view the overlap as 
a compelling reason to require reports to be filed within 30 days of month end.  



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confidential and proprietary registered fund information could be misappropriated as a result of 

unauthorized access.  

While these burden reductions would largely be relative to the 2024 amendments, which 

have not gone into effect, the proposed approach would also reduce burdens associated with the 

30-day recordkeeping requirement that registered funds historically have satisfied. Under the 

recordkeeping requirement, registered funds were required to gather and record Form N-PORT 

information within 30 days of month end. In contrast, the current proposal would not require 

registered funds to complete particular steps within 30 days of month end, rather a complete 

submission of monthly data would be due to the Commission within 45 days of month end. As a 

result, if adopted, the proposed approach would provide funds with more time to gather and 

review information than has historically been available or that would be available under the 2024 

amendments. This additional time would likely reduce burdens, particularly in cases where 

information is collected through a manual or otherwise time-consuming process, such as the 

example raised in outreach about delays in valuation information for certain closed-end funds. 

Moreover, relative to the requirement for registered funds to gather and record Form N-PORT 

information within 30 days of month end, a requirement to file the information with the 

Commission within 45 days of month end should reduce costs because funds that continue to 

gather the required information within 30 days of month end would then have 15 additional days 

just to prepare that information for filing with the Commission. 

 Given the additional information we have received about the challenges and burdens of 

filing Form N-PORT reports within 30 days of month end, as well as the increased risk of errors, 

we considered the effects of additional filing time on the utility of the reported information for 

the Commission and staff. As the Commission recognized in 2024, less timely data reduces the 



19 
 

utility of the information for the Commission. At the same time, data quality issues, such as 

errors in the reported information, can also affect the utility of the data. Overall, we anticipate 

that providing registered funds with 15 additional days to file monthly reports would not have a 

significant negative effect on the utility of the information, and the potential increase in data 

accuracy and reliability could provide benefits to the Commission.  

Specifically, providing an additional 15 days for filing monthly Form N-PORT reports 

would likely not have a significant effect on many of the Commission’s uses of the data, such as 

for monitoring and for risk and trend analysis, and the anticipated improvement in data quality 

would be a net benefit for these purposes. While the less timely data would in some cases reduce 

the utility of Form N-PORT information when market events occur, the monthly filing cadence 

would result in the Commission still having access to relatively recent data from registered 

funds’ most recently filed reports.21 Under the proposal, Form N-PORT information the 

Commission receives would be stale by about a month and a half, while the 2024 amendments 

would result in information that is stale by about a month, and the prior quarterly filing 

requirement resulted in information that is stale by up to five months. As a result, although 

providing registered funds with additional time to file Form N-PORT reports would reduce the 

utility of the information for the Commission, the effect of the additional 15 days to file Form N-

PORT on the utility of the information is generally small and justified by the reduced burden on 

these funds and the anticipated improvement in data quality.  

 
21  For example, if a market event occurred at the end of Dec., a 30-day filing timeline would result in the 

Commission receiving information for the month of Nov. around the time of the market event, while a 45-
day filing timeline would result in the Commission needing to use information for the month of Oct. In 
contrast, if a market event occurred in mid-Dec., the 30-day filing timeline and 45-day filing timeline 
would both result in the Commission needing to use information as of the month of Oct. to help assess the 
effects of the event. 



20 
 

We considered providing more time to file than we are proposing, such as 60 days after 

month end, or requiring monthly reports on a quarterly filing cadence (e.g., with reports for each 

month in a fiscal quarter due 45 or 60 days after quarter end). A longer filing timeframe would 

reduce the utility of the information for staff oversight and analysis, and the associated benefits 

of such activity for investors, because the reported information is increasingly less likely to 

reflect reasonably current portfolio holding-related information as the filing deadline moves 

further away from the end of the month to which the information relates. While we recognize 

that there may be certain efficiencies for registered funds and vendors associated with a quarterly 

filing cadence, as discussed in the 2024 Adopting Release, this approach results in the 

Commission receiving data that is multiple months old and, in past experience, has limited the 

Commission’s ability to develop a timely and more complete understanding of the market, 

thereby impeding its ability to respond to market stresses and events as they are developing. In 

addition, it is unclear that extending the filing timeframe beyond 45 days after month end would 

significantly reduce the risk of errors in reported information, as registered funds already have 

infrastructure for collecting the required information within 30 days after month end. 

Furthermore, in light of the other proposed amendments to the form, we anticipate a reduction in 

reporting burden for most registered funds, which could potentially reduce the need for 

additional time to file Form N-PORT reports. 

We request comment on the proposed changes to the timing and frequency with which 

registered funds would be required to file reports on Form N-PORT, including: 

1. As proposed, should we extend the deadline for filing reports on Form N-PORT 

from 30 days to 45 days after the end of the month? Should we instead retain the 

30-day filing deadline? Should we instead use a different deadline, such as 35 or21 
 

60 days after the end of the reporting month? How would a different deadline 

affect burdens for registered funds and data quality? 

2. To what extent would the additional 15 days to file Form N-PORT, relative to the 

2024 amendments, reduce burdens for registered funds? Would the additional 15 

days to file reduce costs associated with implementation compared to a 30-day 

filing deadline, and, if so, to what extent? Would the additional 15 days to file 

reduce the potential for errors in the reports compared to a 30-day filing deadline, 

and, if so, to what extent? Would the additional 15 days to file reduce strains on 

reporting teams that prepare, review, and file Form N-PORT reports and that are 

also involved with other required filings and reduce the need for registered fund 

advisers or administrators to hire additional personnel, and, if so, to what extent? 

3. Would a 45-day filing deadline affect registered funds that use vendors to prepare 

or file Form N-PORT reports differently than funds that do not use vendors, and, 

if so, in what ways? For funds that use vendors, would a 45-day filing deadline 

provide sufficient time for coordination between funds and vendors?  

4. Are there certain periods of a year where 45 days after month end would not 

provide sufficient time for filing Form N-PORT reports? For example, should we 

provide additional time beyond the proposed 45-day deadline to file Form N-

PORT reports for months that correspond to the end of the registered fund’s fiscal 

year or fiscal half-year, in order to provide more time during periods that funds 

are preparing annual and semiannual reports? If so, how much time (e.g., 60 

days)? How much additional burden would a 45-day deadline impose on 

registered funds during those times relative to other times of the year? Are there 



22 
 

other ways to reduce burden during those times? Should we provide more time to 

file Form N-PORT reports for months that relate to fiscal quarter ends more 

generally? Are there ways to limit the impact on the Commission’s use of Form 

N-PORT information if we were to provide additional time to file for particular 

months? 

5. Would a 45-day filing timeline create new or different burdens for registered 

funds and service providers, relative to a 30-day filing timeline, that we should 

consider? For example, would there be additional burdens associated with 

overlaps in report preparation time (i.e., with a 45-day deadline, the report for 

Month 1 is not due until approximately 15 days after the fund begins to prepare 

the report for Month 2)? 

6. What are the costs and benefits of a monthly filing frequency for smaller 

registered funds? For example, do smaller funds have a high administrative or 

operational cost in preparing these reports disproportionate to their other 

expenses? Would monthly filing of portfolio holdings significantly affect how and 

whether smaller funds can do business? 

7. Should certain types of registered funds, such as closed-end funds or smaller 

funds, have a different amount of time to file Form N-PORT reports or be 

permitted to file on a different frequency? If so, what types of funds should be 

subject to different requirements and what would those requirements be (e.g., 

filing within 30 or 60 days of month end, or filing within 30, 45, or 60 days of 

quarter end)? How would those certain types of funds benefit from different 

requirements? What types of different challenges do these funds face, and would 



23 
 

different requirements reduce those challenges, costs, and burdens? Are there 

ways to limit the impact on the Commission’s use of Form N-PORT information 

if we were to provide a different reporting timeline or frequency for certain 

registered funds? 

8. Is there any specific information that registered funds should have additional time 

to file, such as through an exhibit or attachment to the original filing or a separate 

filing type? If so, what information, and how much time do funds need to compile 

and verify that information? Is there specific information that registered funds 

could file with a high level of accuracy under the current timeline of 30 days after 

month end? Would it be challenging or burdensome for registered funds to file 

information at different intervals?  

9. Should we, as proposed, require registered funds to file reports on Form N-PORT 

on a monthly basis? Should we instead revert to requiring funds to file monthly 

reports on a quarterly basis like the previous requirements, or require funds to file 

reports on a different frequency altogether? If we require funds to file monthly 

reports on a quarterly basis, when should reports be due (e.g., 45 or 60 days after 

quarter end)? 

10. Are there other effects of providing an additional 15 days to file Form N-PORT, 

relative to the 2024 amendments, on registered funds, service providers, investors, 

the Commission, or others that we should take into account? 

11. Should we require registered funds to make records of Form N-PORT information 

within 30 days of month end, as was required prior to the 2024 amendments? 

What would be the effects of providing funds with 45 days to file Form N-PORT 



24 
 

reports without the historical requirement to make records of Form N-PORT 

information within 30 days of month end? Would this effectively result in funds 

having additional time to gather and verify the accuracy of information compared 

to the 30-day recordkeeping requirement? If so, are there certain types of 

information for which the additional time to gather and verify would be 

particularly helpful? Alternatively, would a 45-day filing deadline have limited, or 

no, effect on the timeline for gathering and verifying the accuracy of information 

because of the time needed for filing-related tasks or for other reasons? Are there 

benefits to a 30-day recordkeeping requirement that we should account for in our 

analysis? Would those benefits support adopting a 30-day recordkeeping 

requirement, or a requirement to maintain records within a different timeframe, as 

part of this rulemaking? 

12. Are there feasible alternatives to the proposed requirement to file monthly reports 

within 45 days of month end that would minimize reporting burdens on registered 

funds while maintaining the utility of the information reported to the 

Commission? Does the proposal appropriately balance the utility of the 

information to the Commission in relation to the costs to registered funds and 

their affiliated persons of providing the information?22 Does publication 

frequency or any other aspect of the proposal affect the analysis of these 

questions? 

 
22  See section 30(c)(2) of the Investment Company Act [15 U.S.C. 80a-29(c)(2)] (providing that, if the 

Commission requires information to be filed more frequently than annually under section 30 of the 
Investment Company Act, it shall consider and seek public comment on: (1) feasible alternatives that 
minimize reporting burdens, and (2) the utility of the information to the Commission in relation to 
associated costs). 



25 
 

B. Publication Frequency 

Upon further review of the publication frequency of Form N-PORT, we are proposing to 

require public disclosure of registered funds’ portfolio holdings for the third month of each fiscal 

quarter with a 60-day delay instead of requiring public disclosure of report information for every 

month with a 60-day delay after the end of the relevant month.23 This proposal mirrors the 

publication frequency of portfolio holdings that had been in place since 2004.24 As part of this 

review, we considered issues raised by commenters in connection with the 2024 amendments, 

statements of the petitioner in a challenge of certain of the 2024 amendments in the Fifth Circuit, 

and information provided by market participants following the adoption.25 

The review suggests that the potential effects of more frequent publication of a registered 

fund’s portfolio holdings could be more significant for some funds than the Commission 

previously appreciated.26 Those effects include additional costs that an increased publication 

frequency could impose on some registered funds, especially with the use of advancing 

technology, with a magnified effect on certain types of funds, such as those with actively 

managed strategies. While commenters raised these concerns in connection with the 2024 

amendments, they have also been raised in post-adoption communications.  

 
23  See 2024 Adopting Release, supra note 1, at section II.A.2. 
24  See, e.g., Reporting Modernization Adopting Release, supra note 20 (adopting new Form N-PORT to 

require certain registered investment companies to report information about their monthly portfolio 
holdings and rescinding Form N-Q); Shareholder Reports And Quarterly Portfolio Disclosure Release, 
supra note 2 (adopting Form N-Q and requiring quarterly portfolio holdings disclosure). 

25  See, e.g., 2024 Adopting Release, supra note 1, at section II.A.2; Registered Funds Association v. SEC, No. 
24-60550 (5th Cir. 2024); ICI Letter (suggesting that the Commission should revert to quarterly publication 
of Form N-PORT reports and extend the reporting timeframe to at least 45 days after month end). 

26  The discussion in this section of the release does not relate to ETFs that are required to disclose their 
portfolio holdings on a daily basis under 17 CFR 270.6c-11 (rule 6c-11), as changes to Form N-PORT do 
not affect the frequency at which these funds’ portfolio holdings are made public. See 17 CFR 270.6c-
11(c)(1)(i) and (c)(2).  



26 
 

Specifically, external parties may use information about a registered fund’s portfolio 

holdings to trade in a way that harms the fund.27 While this risk exists with any information 

about a fund’s portfolio holdings, more frequent publication of portfolio holdings may increase 

the risk. External parties may obtain at no cost the benefits of the investment research and 

analysis that went into developing the fund’s investment strategies. For example, external parties 

may exploit a fund’s portfolio holdings information to reverse engineer and copy the strategy, 

often called “free riding.” External parties may also “front run” a fund by using a fund’s 

portfolio holdings information to identify positions that the fund may be acquiring or disposing 

of and trade ahead of the fund. In combination with fund flow information, external parties may 

use portfolio holdings information to front run the sales of funds that experience large outflows 

and purchases of funds with large inflows. These activities may lead to more (or less) demand 

for an investment, which could drive up the price of trading, inhibit the investment adviser’s 

ability to achieve the fund’s investment strategies, and harm fund performance. These risks may 

affect registered funds differently depending on various factors, such as the quality and age of 

the data and characteristics of the fund (e.g., its investment strategy and amount of portfolio 

turnover). 

Registered funds and, indirectly, their shareholders pay investment advisers management 

fees to perform important research and analytical functions, construct funds’ investment 

strategies, and manage funds’ portfolios. Free riding and front running are ways that external 

parties may take advantage of that work without compensating investment advisers. As a result, 

 
27  Commenters and other parties have at times referred to these activities as “predatory trading.” 



27 
 

investment advisers may be less willing to devote resources to research and analysis, which may 

reduce their effectiveness and information production, potentially reducing price efficiency.28 

These risks increase for many actively managed registered funds as technology, such as 

artificial intelligence, evolves, becomes cheaper, and usage increases. For example, an external 

party may use technology tools to aggregate large amounts of data to predict not-yet-completed 

or future portfolio management decisions to free ride on the investment adviser’s work or front 

run the fund.29 Artificial intelligence continues to evolve rapidly and is just one example of 

rapidly advancing developments that may increase the risk of external parties using information 

about a registered fund’s portfolio holdings to trade in a way that harms the fund. The proposed 

amendments would require four publications of portfolio holdings per year, instead of the 

monthly publication frequency required by the 2024 amendments that would result in 12 

publications per year. Along with advances in technology, the 2024 amendments’ quadrupling of 

the amount of available data also could increase the risk that a fund’s proprietary investment 

strategy or trading inventions are inferred by external parties.  

Registered funds vary in how often they voluntarily publish their portfolio holdings 

depending on their sensitivity to transparency and their investment objectives and strategies.30 

While some registered funds frequently release complete portfolio holdings information on their 

websites and to data aggregators, others make more limited portfolio holdings public, such as a 

list of 10 largest holdings, and still others do not provide any voluntary portfolio holdings 

 
28  See infra sections III.D.1 and III.D.3. 
29  See ICI Letter (noting the risks of evolving technologies and artificial intelligence to allow predatory 

traders to accurately analyze and anticipate a registered fund’s next investment transaction or mimic its 
investment strategy, which may affect almost every type of actively managed fund). 

30  See 2024 Adopting Release, supra note 1, at n.230 (discussing a paper estimating that, at year-end 2019, 
approximately 56% of U.S. equity mutual funds’ portfolio disclosures were voluntary monthly disclosures).  



28 
 

information at all. Registered funds may choose to disclose only the required portfolio holdings 

information because additional data may reveal confidences about their investment strategies and 

increase the risk of free riding or front running. For example, certain actively managed, fixed 

income, less liquid, or concentrated investment strategies may require some time to build or 

dispose of portfolio holdings or to find buyers or sellers at the desired target price. This increases 

the risks of other parties trading ahead of the fund before the fund has finished building or 

disposing of a position.  

Under the 2024 amendments, information reported for each month will be made public 

60 days after month end. This delay will mitigate some of the risks of more frequent disclosure 

of registered funds’ portfolio holdings, such as the risks of front running, because a fund will be 

able to build or dispose of a position before a report is made public. However, certain investment 

strategies (such as those that are concentrated and with significant positions) may, at times, need 

more than 60 days to build or dispose of a position. In addition, the 60-day delay may not 

effectively address the risk that publishing a registered fund’s portfolio 12 times a year will 

contribute to free riding, particularly as technology continues to advance.  

We recognize there are benefits of publishing a registered fund’s portfolio holdings on 

Form N-PORT more frequently than the quarterly publication requirement. The Commission 

considered these benefits in the 2024 amendments.31 For example, such transparency allows 

investors to review and monitor information about registered fund portfolio holdings on an 

ongoing basis and may help better inform their investment decisions. It also allows other market 

participants, such as data aggregators and investment advisers, to better advise investors and help 

manage their investment portfolios. More frequent publication of portfolio holdings information 

 
31  See 2024 Adopting Release, supra note 1, at n.103 and accompanying text.  



29 
 

also helps reduce the imbalance of information between different types of investors and market 

participants, some of whom may have access to portfolio holdings information before a quarterly 

Form N-PORT publication.32 While these are some ways that additional transparency could 

benefit investors, the Commission received limited feedback in connection with the 2024 

amendments about whether investors or others would use additional Form N-PORT information 

in these ways.33  

We have considered available information, including the costs and benefits of publication 

frequency of portfolio holdings, and are proposing to require public disclosure of registered 

funds’ portfolio holdings only for the third month of each fiscal quarter with a 60-day delay.34 

This would maintain the quarterly publication frequency of portfolio holdings disclosure that had 

been in place for more than twenty years prior to the 2024 amendments and means that a 

registered fund would have up to five months to build or shrink its positions before its portfolio 

holdings are made public.35 A quarterly frequency would reduce costs, including risks that an 

external party can infer a fund’s proprietary investment strategy or trading intentions, as 

 
32  Exhibits required under Part F of Form N-PORT present portfolio holding information in a Regulation S-X 

compliant format that is consistent with how registered funds have historically presented this information in 
annual and semi-annual reports. Under the proposal, registered funds would continue to file this 
information for their first and third fiscal quarters, no later than 60 days after the end of the quarter. If the 
proposed requirement for registered funds to file monthly reports within 45 days of month end is adopted, 
we anticipate providing a separate submission type on EDGAR for funds to file Part F exhibits within 60 
days of the end of a fund’s first and third fiscal quarters. This would result in separate submission types for 
the monthly reports due within 45 days of month end and the Part F exhibits due within 60 days of first and 
third-quarter end. Historically, registered funds have filed Part F exhibits in connection with publicly 
available Form N-PORT filings because, prior to the 2024 amendments, Part F exhibits were due at the 
same time as those Form N-PORT filings. 

33  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.85 (discussing comment letters 
that supported publishing Form N-PORT reports more frequently than quarterly). 

34  Certain of the reported information, such as information about liquidity, use of derivatives, and 
miscellaneous securities, would remain confidential for all months of a quarter. See General Instruction F 
of Form N-PORT. This aspect of the form is unchanged in this proposal. 

35  For example, if a registered fund’s fiscal quarter ends on Mar. 31, an investment made on Jan. 1 would not 
need to be disclosed until May 30, or 60 days after Mar. 31. 



30 
 

compared to monthly public reporting. Importantly, as public information of portfolio holdings 

has generally increased, these proposed amendments are not intended to inhibit registered funds 

from publishing their portfolio holdings more frequently than quarterly on their websites or 

through data aggregators. The proposal takes into account our review and rebalancing of the 

benefits of information available for investors with the potential harms caused by more frequent 

publication of portfolio holdings, such as free riding or front running.36  

We request comment on the proposed amendments to the publication frequency of 

portfolio holdings on Form N-PORT, including:  

13. How often should portfolio holding information be disclosed publicly? Should 

we, as proposed, require registered funds to publish their portfolio holdings 

quarterly? Should the publication frequency be shortened or lengthened, for 

example, to monthly or semi-annually? What are the costs and benefits of each 

publication frequency? Do retail investors find publication of this information 

helpful and/or useful? If publication of this information is used primarily by 

institutional investors and data aggregators, should we require this information to 

be continued to be made public? 

14. What would be the costs and consequences of quarterly publication of portfolio 

holdings, based on experience with the historic quarterly frequency? Please 

provide concrete examples and data. For example, does the historic quarterly 

publication frequency lead to free riding, front running, or other actions by 

 
36  Section 45(a) of the Act requires information in reports filed with the Commission pursuant to the Act to be 

made public unless we find that public disclosure is neither necessary nor appropriate in the public interest 
or for the protection of investors. For the reasons discussed above, we would view that keeping the data for 
the first and second months of a registered fund’s fiscal quarter confidential, and the data for the third 
quarter confidential until the expiration of the 60-day period provided by the proposal, as necessary or 
appropriate in the public interest or for the protection of investors. 



31 
 

external parties that harm registered funds, and, if so, how, to what extent, and for 

which kinds of funds? Would these actions by external parties affect fund 

performance, and, if so, how? Would these actions reduce research and resources 

spent on research, and, if so, by how much?  

15. What would be the costs and consequences of more frequent than quarterly 

publication of portfolio holdings? Please provide concrete examples and data. For 

example, would more frequent publication increase free riding, front running, or 

other actions by external parties that harm registered funds, and, if so, how? 

Would these actions by external parties affect fund performance, and, if so, how, 

to what extent, and for which kinds of funds? Would these actions reduce research 

and resources spent on research, and if so, by how much? Are there 

administrative, operational, or other costs of more frequent publication of 

portfolio holdings. And if so, what are they? Would some registered funds change 

their investment strategies and other business practices, and, if so, what would the 

changes be? How many, and what kinds of, funds would be affected, and what 

would the effects be? Please provide concrete examples and data. 

16. What are the benefits of more frequent publication of portfolio holdings than a 

quarterly frequency? Please provide concrete examples and data. For example, 

how do investors, other market participants, such as data aggregators and 

financial intermediaries, and the broader market use or plan to use portfolio 

holdings information? How do they use portfolio holdings information to inform 

their investment decisions or perform other tasks? How does standardized 

information in a central location, as opposed to individual websites, benefit 



32 
 

investors and other market participants? Do registered funds voluntarily publish 

data about their portfolios to compete for investors? How does the publication of 

portfolio holdings information improve market efficiency? 

17. Should we publish monthly portfolio holding information on Form N-PORT, but 

with a longer delay than provided in the 2024 amendments? For example, should 

monthly reports be made public 90 days after the end of the reporting period? 

Should monthly reports for each month in a fiscal quarter be made public at the 

same time, such as 60 or 90 days after the end of the fiscal quarter? Would 

delaying publication of monthly reports reduce the risks of free riding, front 

running, or similar actions relative to the 2024 amendments? Would this type of 

delayed dissemination of monthly information benefit investors?  

18. How have market participants used technology, including artificial intelligence, in 

connection with portfolio holdings information? Is the information used in ways 

that increase free riding, front running, or similar actions and adversely affect 

registered funds and their shareholders? If so, who has used the information, and 

in what ways, and how has this use affected funds and shareholders? Please 

provide concrete examples of which kinds of funds have been affected and what 

the effects have been, and any related data. Is this usage expected to increase or 

change in the future, and if so, in what ways, and how much? How would more or 

less frequent disclosure of registered funds’ portfolio holdings information affect 

these uses? Conversely, is the information used in ways that improve investor 

choice, information, and experience or otherwise benefit investors? 



33 
 

19. What types of registered funds are more adversely affected by more frequent 

publication of portfolio holdings? How are they affected? Should certain funds, 

for example, smaller or actively managed funds, or closed-end funds or non-

diversified funds, be exempt or have different treatment in publication of portfolio 

holdings? What type of exemption or changes would suffice, for example, longer 

confidential treatment? If so, for what longer period should information remain 

confidential? Would investors and market participants suffer harm from or 

disadvantages from a longer period, and if so, how? For registered funds that are 

less likely to be adversely affected, should the Commission retain the monthly 

publication timing adopted in 2024?  

20. Should publication be required on calendar quarter-end instead of fiscal quarter-

end? What are the costs and benefits of moving to a calendar quarter-based 

publication frequency? For registered funds with fiscal year ends that do not 

match a calendar quarter, how could requirements for the publication of portfolio 

holdings be changed to minimize additional publications as the result of annual 

and semi-annual shareholder reports?  

21. How long should the period for publication delay be? Should the delay be 

shortened or lengthened, for example, to 45, 75, or 90 days? What are the costs 

and benefits of a 60-day or other period of delay? Please provide concrete 

examples and data. For example, how does the current 60-day delay affect the 

risks of free riding, front running, or similar actions? How would a shortened or 

lengthened timeframe affect these risks? What other effects would a different 

timeframe have on fund performance? 



34 
 

22. Are there other amendments to Form N-PORT that would reduce compliance 

burdens and the risks of disclosing portfolio holdings? For example, should the 

percentage of assets allowed to be reported non-publicly on Form N-PORT as 

miscellaneous securities (Part D) be lower or higher than the current 5% limit, for 

example, 3%, 8%, or 10%? What would the costs and benefits be of amending 

this or any other reporting requirement? 

23. Do investors or others use the presentation of portfolio holdings that registered 

funds provide under Part F of Form N-PORT for their first and third fiscal 

quarters? Are there ways we could make the Part F information more user-

friendly or less costly for funds to prepare?37 For example, are there other ways to 

disclose the portfolio information in Part F that would facilitate the use of 

artificial intelligence or other tools to analyze the portfolio holdings information, 

and if so, how? As another example, should we require only certain holdings but 

not the complete portfolio holdings, and, if so, which holdings? For instance, 

should we require presentation of a certain number of the largest issues (e.g., 10, 

25, or 50) and any other issues that exceed a particular percentage of the 

registered fund’s net asset value (e.g., 1% or 5%)? Should we require each 

registered fund to provide a graphical representation of holdings for reports 

covering the end of the first and third quarters of the fund’s fiscal year, similar to 

the graphical representations of holdings provided in funds’ annual and 

 
37  See 2024 Adopting Release, supra note 1, at section II.A.3 (discussing comments on the burdens of 

providing a Regulation S-X compliant presentation of portfolio holdings more frequently than Form N-
PORT requires). 



35 
 

semiannual shareholder reports?38 Is there other information that would be helpful 

to investors in a more user-friendly presentation for these quarter ends, such as a 

registered fund’s net assets, total number of portfolio holdings, or other fund 

statistics?39 Are there other tools that would be helpful to investors in 

understanding and analyzing a fund’s portfolio holdings, for example, artificial 

intelligence tools on registered funds’ websites, that would decrease the need for 

Part F? If so, what kinds of tools would serve this purpose, and which information 

could be removed from Part F? If the information that registered funds currently 

provide under Part F is not typically useful to investors or others, should we 

remove Part F from Form N-PORT? Certain Commission rules reflect that, due to 

Part F requirements, registered funds prepare schedules of their complete 

portfolio holdings for the close of their first and third fiscal quarters in a 

Regulation S-X compliant format.40 If we amend or remove Part F of Form N-

PORT, should we likewise amend or remove associated requirements from these 

other rules?  

 
38  See, e.g., Item 27A(f) of Form N-1A (requiring a graphical representation of holdings in annual and 

semiannual shareholder reports of funds that register on Form N-1A). 
39  See, e.g., Item 27A(e) of Form N-1A (requiring funds that register on Form N-1A to provide certain fund 

statistics in their annual and semiannual shareholder reports, and allowing these funds to provide additional 
statistics that the fund believes would help shareholders better understand the fund’s activities and 
operations, such as tracking error, maturity, duration, average credit quality, or yield). 

40  See, e.g., 17 CFR 270.30e-1(b)(2)(ii) (requiring, among other things, that an open-end fund registered on 
Form N-1A (other than a money market fund) make available on its website the fund’s complete portfolio 
holdings as of the close of the most recent first and third fiscal quarters, presented in accordance with 
Regulation S-X); 17 CFR 270.30e-3(b)(1)(iv) (permitting a management company registered on Forms N-2 
or N-3 to send a notice of website availability of a fund’s shareholder reports to satisfy shareholder report 
transmittal requirements if certain conditions are met, including website availability of the fund’s complete 
portfolio holdings as of the close of the most recent first and third fiscal quarters, presented in accordance 
with Regulation S-X). 



36 
 

C. Other Proposed Amendments to Form N-PORT 

In addition to the proposed amendments to provide registered funds with fifteen 

additional days to file monthly reports and to revert to the quarterly publication frequency, we 

are proposing amendments to Form N-PORT to refine the information funds provide while 

maintaining the usability and reliability of Form N-PORT data. Specifically, we are proposing to 

modify certain information collected on portfolio level risk metrics and returns to narrow their 

scope, and proposing to eliminate certain information collected on registered funds’ compliance 

with names-related regulatory requirements, payoff profiles of non-derivatives instruments, 

convertible bonds, and the reason a single holding has multiple liquidity classifications. We are 

also proposing to modify how funds with ETF share classes report net assets and shareholder 

flows to require separate information for ETF share classes. Additionally, we are proposing to 

require registered funds to provide certain additional identifying information, such as ticker 

symbols and certain class-level information, as applicable. The key aspects of the proposed 

amendments are described in Table 2 below and discussed in more detail throughout this section. 

Table 2. Comparison of Current and Proposed Requirements 

 Current Requirement Proposed Requirement 
Portfolio Level Risk Metrics 
Scope of registered funds that 
must report  

The average value of the 
fund’s debt securities 
positions for the previous 3 
months, in the aggregate, 
exceeds 25% of the fund’s net 
asset value 

The average value of the 
fund’s debt securities 
positions for the previous 3 
months, in the aggregate, 
exceeds 50% of the fund’s net 
asset value 

Interest rate risk metrics Report both DV01 and 
DV100 
 
Report DV100 separately for 
each currency for which the 
fund had a value of 1% or 
more of the fund’s net value 

Report DV100 only 
 
 
Report DV100 aggregated 
across all currencies for 
which the fund had a value of 
1% or more of the fund’s net 
asset value 



37 
 

 Current Requirement Proposed Requirement 
Credit spread risk metrics Report separately for 

investment grade and non-
investment grade exposures 

Aggregate investment grade 
and non-investment grade 
exposures 

Return Information 
Reporting by multiple class 
funds 

Report separately for each 
class 

Report for a single 
representative class 

Calculating returns Calculate in accordance with 
methodologies outlined in 
applicable registration form 

Calculate in accordance with 
methodologies outlined in 
applicable registration form, 
except do not deduct sales 
loads and redemption fees 

Reporting net realized gain 
(loss) and net change in 
unrealized appreciation 
(depreciation) attributable to 
derivatives 

Report separately by asset 
category and, within each 
asset category, further report 
by type of derivative 
instrument 

Report separately by asset 
category only 

Period of return information 
covered in each report (same 
change also made for flow 
information) 

One month Each of the preceding three 
months, in light of the 
proposed quarterly 
publication frequency 

Items for Elimination 
Names rule information (1) Definitions of the terms 

used in a registered fund’s 
name;  

(2) The value of the fund’s 
80% basket, as a 
percentage of the value of 
the fund’s assets;1 and  

(3) Whether each investment 
in the fund’s portfolio is 
in the fund’s 80% basket 

None 

Payoff profile for non-
derivatives 

Indicate payoff profile among 
the following categories 
(long, short, N/A) 

None 

Convertible securities 
information 

Report conversion ratio and 
delta (if applicable) 

None 

Multiple liquidity 
classifications 

If attributing multiple 
liquidity classifications to a 
single holding, indicate which 
of three possible 
circumstances is applicable 

None 

ETF Share Class Reporting 
Separate information reported 
for ETF share classes 

None Report net assets and flow 
information separately for the 



38 
 

 Current Requirement Proposed Requirement 
ETF share class, as well as 
the class’s ticker 

Identifying Information 
Provide ticker and certain 
class-level information, as 
applicable 

Registered funds report class 
identification numbers in 
connection with reporting 
class-level returns2 

Report ticker symbol by 
registrant, and for each class 
of a registrant or series, as 
applicable, as well as class 
names and class identification 
numbers. 

Notes: 
 
1. The names rule requires certain funds to adopt a policy to invest at least 80% of the value of their assets in 
accordance with the investment focus that a fund’s name suggests. In 2023, the Commission adopted 
amendments to broaden the scope of this requirement and to define “80% basket” generally as investments that 
are invested in accordance with the investment focus that a fund’s name suggests (“names rule amendments”). 
See rule 35d-1(g) under the Act. 
 
2. The proposed amendments would change this reporting and only require returns for a single representative 
class on Form N-PORT. 
 

 
 

Portfolio Level Risk Metrics 

Registered funds that invest certain amounts of their portfolios in debt instruments, or 

derivatives that provide exposure to debt instruments, currently are required to report specific 

portfolio level risk metrics on Form N-PORT.41 The reported risk metrics are intended to provide 

the Commission staff, investors, and other potential users with measures that can help them 

analyze how portfolio values might change in response to changes in interest rates or credit 

spreads.42 We are proposing to raise the threshold for determining which registered funds are 

required to report portfolio level risk metrics and to streamline the metrics they are required to 

report.43 Based on our experience using Form N-PORT data, as discussed below, the proposed 

 
41  See Item B.3 of current Form N-PORT. 
42  See Reporting Modernization Adopting Release, supra note 20, at section II.A.2.c. 
43  See Item B.3 of proposed Form N-PORT. 



39 
 

changes would not significantly affect the utility of the reported information about portfolio level 

risk metrics but would reduce burdens for funds.  

Registered funds are currently required to provide portfolio level risk metrics if the 

average value of the fund’s debt securities positions for the previous three months, in the 

aggregate, exceeds 25% of the fund’s net asset value. We are proposing to increase this reporting 

threshold from 25% to 50%. Registered funds that fall below the proposed threshold would no 

longer be required to provide information on portfolio level risk metrics. The proposed change to 

the threshold is designed to focus the risk metrics reporting requirement on funds with more 

significant exposure to debt securities to better balance the benefits and costs of the reporting. 

Registered funds that invest more than 50% of their net assets in debt securities, averaged over a 

three-month period, are more significantly exposed to changes in interest rates or credit spreads 

and associated changes in the funds’ portfolio values, in comparison to registered funds that 

invest at the 25% threshold. Setting the threshold at the higher 50% level would provide 

Commission staff, investors, and other potential users with more focused measures to help them 

analyze how portfolio values might change in response to changes in interest rates or credit 

spreads for registered funds that invest significantly in debt instruments, or in derivatives that 

provide exposure to debt instruments. 

We also propose to eliminate one risk metric and simplify the reporting of the other 

required risk metrics. Currently, registered funds are required to report two interest rate risk 

metrics, DV01 and DV100. DV01 reflects the change in value of a fund’s portfolio resulting 

from a 1 basis point change in interest rates, while DV100 reflects the change in value from a 

100 basis point change in interest rates. The Commission previously determined to require 



40 
 

registered funds to report both measures because, combined, they show how a fund’s exposure 

changes with different changes in interest rates and thus provide information about convexity.44  

Based on staff experience using Form N-PORT information, and given that our receipt of 

Form N-PORT information is delayed, we propose to eliminate the DV01 metric, which is 

typically used as a daily risk measure. Registered funds currently are required to report this 

metric for each currency for which the fund had a value of 1% or more of its net assets and report 

the metric across multiple maturities. In our experience, the DV100 metric that registered funds 

report has been more useful in monitoring funds’ exposures to interest rate risk over time. 

DV100 is among the most common measures of interest rate sensitivity, allows the staff to 

capture larger changes to interest rates (and corresponding “shocks” to the markets), and 

provides useful information about non-parallel shifts in the yield curve as compared to smaller 

measures like DV01. In addition, DV100 on its own provides some information about convexity 

because it measures larger changes in interest rates, and it can be combined with other 

information that registered funds report (such as the prevalence of holdings in certain instrument 

types, like zero coupon bonds and mortgage-backed securities) to monitor convexity.  

We also propose to simplify the reporting of the DV100 metric by requiring registered 

funds to report the aggregate change in the value of the portfolio from a 100 basis point change 

in interest rates across all applicable currencies (i.e., those that are 1% or more of the fund’s net 

asset value), rather than providing separate changes in value for each of those currencies. The 

Commission required DV100 for each applicable currency to help understand interest risk for 

 
44  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.155. The 

Commission also discussed that some filers may not calculate convexity internally, so requiring the two 
interest rate metrics was designed to mitigate the increase in reporting costs that would be associated with 
requiring registered funds to separately report a measurement of convexity.41 
 

registered funds with significant currency risk.45 Based on our experience, we can use other 

information reported on the form, such as the currency denomination of each portfolio holding, 

to help assess significant currency risk in conjunction with the aggregate DV100 information that 

funds would report under the proposal.46   

In addition, we propose to streamline the information reported on credit spread risk by no 

longer requiring registered funds to report credit spread risk metrics separately for investment 

grade and non-investment grade exposures. The Commission required separate reporting for 

investment grade and non-investment grade debt because credit spreads for investment grade and 

non-investment grade debt do not always shift in parallel or lock step, particularly in times of 

stress.47 Based on our experience, we can use information we separately receive on Form N-

PORT about debt securities’ coupons as a proxy for a registered fund’s relative exposures to 

investment grade and non-investment grade debt, as these different categories of debt generally 

have different coupon levels to account for their differing levels of risk. This information, 

combined with aggregated credit spread metrics under the proposal, would continue to provide 

information about credit spreads, and the risk associated with credit spreads.  

We are also proposing to require information about portfolio risk metrics to be reported 

in U.S. dollars for consistency in reporting. Consistent reporting, in turn, makes the information 

more useable and facilitates comparisons across registered funds. The proposed instruction is 

consistent with many registered funds’ current practices and aligns with how funds report 

changes in the value of the portfolio elsewhere in the form. Additionally, we understand that the 

 
45  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.148. 
46  See Item C.2 of current Form N-PORT (requiring registered funds to report the currency in which each 

investment is denominated). 
47  See Reporting Modernization Adopting Release, supra note 20, at text accompanying n.159. 



42 
 

proposed instruction is consistent with a common interpretation of DV100, with “DV” being an 

abbreviation for “dollar value.” When a registered fund reports portfolio level risk metrics in 

currencies other than U.S. dollars—particularly when the exchange rate between a given 

currency and U.S. dollars is significantly different from an exchange rate of 1.00—the fund’s 

risk metric values are more likely to be outside the range of typical risk metric values reported in 

U.S. dollars by similar funds, which has the potential to cause investor confusion and has 

negatively affected staff use of the reported information.   

The proposed amendments to risk metric reporting would, to a certain degree, reduce 

information for understanding and monitoring registered funds’ exposures to changes in interest 

rates and credit spreads across the yield curve. In particular, there would be less information 

about these exposures for registered funds with marginal or temporary exposure to debt 

securities, and somewhat less granular risk metric information for funds with more significant 

exposures to debt securities. However, the proposed changes would not significantly affect how 

the Commission uses Form N-PORT data, and the public would continue to have access to 

information about registered funds’ significant interest rate and credit spread risks from the form. 

On balance, the proposed amendments to portfolio level risk metrics would simplify registered 

fund reporting and reduce burdens while maintaining useability and reliability of Form N-PORT 

data. 

Return Information 

Currently, registered funds are required to report monthly total returns and, if the fund 

has multiple classes, to report returns for each class.48 For purposes of Form N-PORT, registered 

funds calculate returns using the same standardized formulas required for fund prospectuses and 

 
48  See Item B.5 of current Form N-PORT. 



43 
 

sales materials. The return information reported on Form N-PORT is intended to facilitate 

comparisons across registered funds and to help identify performance that appears inconsistent 

with a fund’s strategy or other benchmarks as a basis for further inquiry and monitoring.49  

We are proposing to simplify reporting by multiple class funds and to provide more 

specific instructions for calculating returns.50 We are also proposing to streamline information 

registered funds currently must report about gains (losses) or appreciation (depreciation) 

attributable to derivatives. Finally, in connection with revisiting the 2024 amendments and 

proposing to return to a quarterly publication frequency, we are proposing to require registered 

funds to report return and flow information for the three preceding months in a single report as 

was the requirement before the 2024 amendments to provide investors access to monthly data for 

a given quarter. (This requirement was removed as a part of the 2024 amendments because the 

amendments to the publication frequency gave investors access to monthly Form N-PORT 

reports.) 

Currently, multiple class funds are required to report monthly total returns and related 

identifying information for each class of the fund. We propose to require that multiple class 

funds report information for a single representative class rather than return information for each 

class within a fund. Under the proposal, the representative class would be selected in the same 

manner that Form N-1A registrants use to determine which class’s annual total returns to 

disclose in fund prospectuses. Using this approach, a registered fund can select which class to 

use as its representative class (e.g., the oldest class, the class with the greatest net assets), except 

the fund must: (1) select the class with 10 or more years of annual returns if other classes have 

 
49  See Reporting Modernization Adopting Release, supra note 20, at section II.A.2.e. 
50  See Item B.5 of proposed Form N-PORT. 



44 
 

fewer than 10 years of annual returns; and (2) select the class with the longest period of annual 

returns when the classes all have fewer than 10 years of returns.51 Based on our experience with 

the data, having return information for a single representative class of a multiple class fund 

should be sufficient for purposes of comparing registered funds and identifying performance that 

appears inconsistent with a fund strategy or other benchmarks, as returns across classes of a 

multiple class fund are generally consistent except for the effects of certain class-specific fees 

and expenses, and as discussed below, we are specifying that certain of these differences should 

not be accounted for in monthly returns reported on Form N-PORT. Moreover, certain 

performance information for all classes would remain available in fund prospectuses for an 

investor making an investment decision about the appropriate class in which to invest.  

We are also proposing to specify that registered funds should not deduct sales loads and 

redemption fees charged to shareholder accounts when calculating monthly returns.52 This 

approach is consistent with many funds’ current practices and consistent with prior staff 

guidance.53 Currently, total returns are to be reported in accordance with the methodologies 

outlined in applicable registration forms. The methodologies in Forms N-1A and N-3 require that 

sales loads and redemption fees charged to all shareholder accounts be deducted when 

calculating returns. The performance disclosures that Forms N-1A and N-3 require show the 

effects of these loads and fees for non-cumulative periods of one, five, and ten-years, while the 

information Form N-PORT provides is monthly. Deducting sales loads and redemption fees for 

each month over an indefinite number of reports could give investors the impression that these 

 
51  See Instruction 3(a) to Item 4(b)(2) of Form N-1A. 
52  See Item B.5 of proposed Form N-PORT. 
53  See Investment Company Reporting Modernization Frequently Asked Questions (Apr. 21, 2021) available 

at https://www.sec.gov/about/divisions-offices/division-investment-management/accounting-disclosure-
information/investment-company-reporting-modernization-frequently-asked-questions. 



45 
 

are ongoing fees and overstate their effect on performance. As a result, we are proposing to 

require that registered funds not deduct sales loads and redemption fees from the returns reported 

on Form N-PORT to provide for consistency across registered fund reporting and to avoid 

overstating the effects of sales loads and redemption fees in monthly return information reported 

on the form. 

In addition to monthly total returns, registered funds are currently required to report the 

net realized gain (loss) and net change in unrealized appreciation (depreciation) attributable to 

derivatives by asset category (e.g., commodity contracts, credit contracts, equity contracts), and 

within those asset categories, funds are required to report the same information for different 

types of derivative instruments (e.g., forward, future, option, swap). This derivative-related 

reporting is intended to help Commission staff, investors, and other potential users better 

understand how a registered fund is using derivatives to accomplish its investment strategy and 

the impact of derivatives on fund returns.54 We propose to eliminate the requirement that 

registered funds report the information by type of derivative instrument. As a result, registered 

funds would not need to separately report return information for each instrument type (e.g., 

equity options and equity swaps), and instead would report information only by asset class (e.g., 

equity contracts). Removing the need to separately report gain (loss) and appreciation 

(depreciation) information for each type of derivative instrument within a given asset category 

would reduce reporting burdens without significantly affecting the utility of the reported 

information, as the Commission and the public would continue to have derivatives-related 

information elsewhere on the form, such as the types and amounts of derivatives instruments the 

registered fund holds, to understand the impact of derivatives on fund returns. 

 
54  See Reporting Modernization Adopting Release, supra note 20, at section II.A.2.e. 



46 
 

Finally, because we are proposing to require that Form N-PORT reports be made public 

only for the third month in a fund’s fiscal quarter, rather than monthly, we likewise are proposing 

to require registered funds to report return information for each of the preceding three months in 

each report to avoid unintended effects on investor’s access to monthly return information, 

similar to how registered funds reported prior to the 2024 amendments. Prior to the 2024 

amendments, registered funds were required to report return information for each of the 

preceding three months in each report to provide investors access to monthly data for a given 

quarter since investors only had access to Form N-PORT reports for the third month of each 

quarter. In connection with requiring publication of monthly Form N-PORT reports in the 2024 

amendments, the Commission modified the form to require return information in each report 

only for the month that the Form N-PORT report covers because the amendments provided 

investors access to each monthly report. Our proposed approach would continue to provide 

investors with “batched” access to monthly return data for a given quarter, consistent with the 

Commission’s historical approach of requiring that investors have access to monthly return 

information on Form N-PORT regardless of the publication frequency. For the same reason, we 

are also proposing to require registered funds to report flow information for each of the 

preceding three months in a single Form N-PORT report.55 

Eliminating Reporting Items  

In addition to proposing to streamline the reporting of some information, we propose to 

remove certain required information from the form. Specifically, we are proposing to remove 

requirements to report information related to the registered fund’s compliance with the names 

rule, the payoff profiles of non-derivatives, certain information about convertible debt securities, 

 
55  See Item B.6 of current Form N-PORT; Item B.6 of proposed Form N-PORT. 



47 
 

and explanations of why a single investment has multiple liquidity classifications. Removing 

these requirements would not have a significant effect on the Commission’s uses of the data and 

are not expected to significantly affect the public’s ability to assess relevant information about 

the fund. 

The names rule amendments, among other things, broadened the scope of the requirement 

for certain funds to adopt a policy to invest at least 80% of the value of their assets in accordance 

with the investment focus that the fund’s name suggests (an “80% investment policy) and added 

reporting requirements on Form N-PORT related to a registered fund’s compliance with that 

rule.56 For a registered fund that is required to adopt an 80% investment policy under the names 

rule, the names rule amendments require the fund to report quarterly on Form N-PORT: (1) 

definitions of terms used in the fund’s name; (2) the value of the fund’s 80% basket, as a 

percentage of the value of the fund’s assets; and (3) whether each investment in the fund’s 

portfolio is in the fund’s 80% basket.57 We are proposing to eliminate these names rule-related 

reporting requirements on Form N-PORT.58  

The purpose of the names rule-related reporting requirements is to provide market-wide 

insight with respect to those registered funds that are subject to the 80% investment policy 

requirement for the Commission, its staff, and market participants. When these requirements 

were adopted, the Commission stated that, by providing context through the definitions used in 

the fund’s name, combined with the value of the fund’s investments in the 80% basket and 

whether each investment in the fund’s portfolio is in the fund’s 80% basket, investors and the 

 
56  See rule 35d-1 under the Act; see also Names Rule Adopting Release, supra note 10, at section II.E 

(discussing Form N-PORT names rule-related reporting requirements). 
57  See Items B.11 and C.2.e of current Form N-PORT. 
58  In addition, we propose to make conforming changes to General Instruction A of Form N-PORT to remove 

references to these Items. 



48 
 

Commission could use this information to better understand how funds have invested in 

compliance with their 80% investment policies.59 Beyond the Form N-PORT requirements, there 

are other sources of information to help investors, the Commission, and its staff understand how 

a registered fund invests in accordance with the names rule, including fund prospectuses and 

portfolio information. For example, the names rule amendments also require a fund to define the 

terms used in its name, including the criteria the fund uses to select the investments that the term 

describes, in its prospectus. In addition, the amendments require a fund to retain records that are 

available to the Commission and its staff, documenting whether an investment is included in its 

80% basket and, if so, the basis for including that investment in the 80% basket.60  

The Commission considered the costs of reporting requirements in the Names Rule 

Adopting Release. Since then, some funds have begun to work toward implementation of these 

requirements and, in conversations with staff, have raised concerns that the reporting 

requirements are more burdensome than anticipated and may have unintended effects. There are 

operational burdens associated with this reporting, such as building connections between 

different internal and external data systems (including, for example, vendor systems or systems 

of subadvisers) and translating that data from various systems for filing, as well as preparing, 

reviewing, tagging, and filing the information on Form N-PORT. Further, while the names rule 

amendments preserved flexibility for the specific criteria a fund uses to select the investments 

that the term in its name describes, and did not require funds to disclose in their prospectuses 

proprietary criteria used to select investments, reporting on Form N-PORT whether an 

investment is in a registered fund’s 80% basket may provide insight into otherwise proprietary 

 
59  See Names Rule Adopting Release, supra note 10, at sections II.E.1 and II.E.2.  
60  See id. at section II.F. 



49 
 

investment criteria because it will provide specific information about what is included in the 80% 

basket.61 This more specific information may allow other market participants to free ride or front 

run the registered fund’s strategy and may harm fund performance. 

These considerations lead us to propose to eliminate the names rule-related reporting on 

Form N-PORT to avoid potential unintended effects and reduce costs while still providing ways 

for the Commission and the public to understand how a fund invests in accordance with the 

names rule. Although the names-related reporting on Form N-PORT would facilitate the 

Commission’s analysis of a registered fund’s compliance with the names rule, the Commission 

can continue to assess compliance with the names rule through analysis of a fund’s disclosures 

about the terms used in its name, including the criteria the fund uses to select the investments 

that the term describes, combined with portfolio holdings. The Commission also can assess 

compliance with the rule through examinations when appropriate, including by analyzing 

required records documenting whether an investment is included in a fund’s 80% basket and, if 

so, the basis for including that investment in the 80% basket. Although the names rule-related 

reporting on Form N-PORT would provide more specific insight to the public into how funds 

have invested in compliance with their 80% investment policies, the public would continue to 

have access to enhanced disclosures in a fund’s prospectus regarding its 80% investment policy, 

which would provide the public with additional context on the fund’s investments and risks in 

plain English. Finally, the public would continue to have access to information about a fund’s 

 
61  See Names Rule Adopting Release, supra note 10, at n.92 and accompanying text (stating that the amended 

rule provides fund managers with flexibility to ascribe reasonable definitions for the terms used in a fund's 
name and to determine the specific criteria the fund uses to select the investments that the term describes, 
which means a fund would not be required to include proprietary information in its 80% investment policy 
in its prospectus). 



50 
 

portfolio holdings in annual and semi-annual reports, in public Form N-PORT reports, and on 

fund websites. 

With respect to payoff profiles for non-derivatives, the form currently requires registered 

funds to report whether each position is long or short.62 The purpose of the payoff profile 

reporting is to identify short positions held by registered funds, consistent with the current 

requirement in Regulation S-X to disclose investments sold short.63 Under the proposed 

amendment, registered funds would not need to classify non-derivative positions as long or short 

for the purposes of reporting on Form N-PORT. We are proposing to remove this reporting 

because the Commission and the public can use the sign of the value of the holding 

(positive/negative) as a proxy for whether holdings are long or short.64 As a result, removing the 

payoff profile item for non-derivatives would have a limited effect on the utility of Form N-

PORT reports. 

For convertible debt securities, registered funds are required to provide information on 

the conversion ratio as well as the delta (if applicable), among other information.65 The purpose 

of this reporting is to help understand the risk and reward profiles of convertible debt securities. 

We propose to simplify reporting of convertible debt securities by no longer requiring registered 

funds to provide the conversion ratio or delta. We have not found this information as helpful as 

 
62  See Item C.3 of current Form N-PORT. Form N-PORT also allows registered funds to report N/A in this 

field, generally for derivatives because the payoff profiles for derivatives are reported in a separate portion 
of the form. 

63  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.267; 17 CFR 
210.12-12A. 

64  Registered funds report the value of each investment under Item C.2 of Form N-PORT. Funds generally 
report positive values for long positions and negative values for short positions. For example, for Dec. 2024 
filings, only 0.0040% of non-derivative long positions were reported with a negative value and 0.0012% of 
short positions were reported with a positive value. 

65  See Item C.9 of current Form N-PORT. 



51 
 

originally contemplated, and we are able to use information about the underlying reference 

instrument for most of our monitoring and analytical purposes. Moreover, funds may use 

different methodologies for calculating delta for convertible bonds, which adds to variability in 

the reported information and reduces its utility.66 

When reporting liquidity classifications for each portfolio holding, an open-end fund is 

permitted to attribute multiple classifications to a single holding under specified circumstances.67 

Currently, if an open-end fund reports multiple liquidity classifications for a single holding, it is 

required to indicate in its Form N-PORT report which of the three listed circumstances led to the 

use of multiple classifications. We propose to eliminate the requirement that funds indicate a 

reason for reporting multiple liquidity classifications for a single holding. The purpose of this 

requirement was to facilitate more effective Commission monitoring of the liquidity of a fund’s 

portfolio and the ability to determine the circumstances leading to the classification.68 Based on 

our experience with this reporting, it is quite rare for open-end funds to report multiple liquidity 

classifications for a single holding. When funds have reported multiple liquidity classifications 

for a single holding, we have not found the reported reasons to be significantly helpful because 

the circumstances in which open-end funds are permitted to use multiple liquidity classifications 

 
66  Delta information reported on Form N-PORT is nonpublic. As a result, removing the delta for convertible 

debt securities would not affect the public’s use of Form N-PORT information. While the conversion ratio 
is made public, we are not aware of public uses of Form N-PORT information that would be significantly 
affected by the removal of the conversion ratio. 

67  See Instruction to Item C.7 of current Form N-PORT. Specifically, an open-end fund may choose to report 
multiple liquidity classifications for a single holding only in the following circumstances: (1) if portions of 
the position have differing liquidity features that justify treating the portions separately; (2) if a fund has 
multiple sub-advisers with differing liquidity views; or (3) if the fund chooses to classify the position 
through evaluation of how long it would take to liquidate the entire position (rather than basing it on sizes it 
would reasonably anticipate trading).  

68  See Investment Company Liquidity Disclosure, Investment Company Act Release No. 33142 (June 28, 
2018) [83 FR 31859 (July 10, 2018)], at section II.B.1. 



52 
 

for a single holding are limited and specifically outlined in the form.69 As a result, we are 

proposing to remove this requirement. Under the proposal, open-end funds would, however, 

continue to be permitted to report multiple liquidity classifications (if any) under the 

circumstances identified in the form. 

Information on ETF Share Classes and Additional Identifier Information for all 

Registered Funds 

For multiple-class funds that offer an ETF share class, we are proposing to require 

disclosures about the ETF share class’s net assets and flows on Form N-PORT.70 Starting in the 

early 2000s, the Commission granted one fund sponsor exemptive relief to offer an ETF share 

class as one class of an open-end, multi-class fund, subject to various terms and conditions.71 In 

the past few years, the Commission has received many exemptive applications from fund 

sponsors seeking a similar ability to offer ETF share classes. The Commission has begun 

granting exemptive relief in response to these applications.72 As a result, it is likely that ETF 

share classes will grow in number and net assets, and information about ETF share classes’ 

expanding size and flows will become more important. The proposed disclosures would facilitate 

 
69  Liquidity classification information reported on Form N-PORT is nonpublic. As a result, removing this 

item would not affect the public’s use of Form N-PORT information. 
70  Form N-PORT currently requires information on net assets and flows for the registered fund as a whole and 

not on a class-by-class basis. See Items B.1 and B.6 of current Form N-PORT. 
71  See Vanguard Index Funds, et al., File No. 812-12094, Investment Company Act Rel. Nos. 24680 (Oct. 6, 

2000) (notice) and 24789 (Dec. 12, 2000) (order); Vanguard Index Funds, et al., File No. 812-12912, 
Investment Company Act Rel. Nos. 26282 (Dec. 2, 2003) (notice) and 26317 (Dec. 29, 2003) (order); 
Vanguard International Equity Index Funds, et al., File No. 812-12860, Investment Company Act Rel. Nos. 
26246 (Nov. 3, 2003) (notice) and 26281 (Dec. 1, 2003) (order); and Vanguard Bond Index Funds, et. al., 
File No. 812-13336, Investment Company Act Release Nos. 27750 (Mar. 9, 2007) (notice) and 27773 (Apr. 
2, 2007) (order).  

72  See DFA Investment Dimensions Group Inc., Dimensional Investment Group Inc., Dimensional ETF Trust 
and Dimensional Fund Advisors LP, File No. 812-15484, Investment Company Act Release Nos. 35770 
(Sept. 29, 2025) (notice) and 35786 (Nov. 17, 2025) (order).  



53 
 

the Commission’s and the public’s understanding of the growth of the industry and inform any 

future Commission action. 

We are proposing amendments to Form N-PORT to require registered funds with an ETF 

share class to report the following: 

• Size. The amendments would require separate reporting of net asset information for 

the ETF share class.73 

• Flows. The amendments would require separate reporting of information about the 

total net asset value of shares sold and total net asset value of shares redeemed or 

repurchased for the ETF share class.74 

These disclosure requirements are designed to provide investors and the Commission 

information about the ETF share class structure by measuring their net assets and flows, 

separately from the fund as a whole. This information is important because an ETF share class is 

structured and may behave differently than the other share classes in a multiple-class fund. 

Separate information for an ETF share class also would facilitate staff analysis of industry trends 

and risks given these structural differences. As an example, ETFs may present different liquidity 

risks than mutual funds, as shares of an ETF can be traded on an exchange throughout the day 

and, when authorized participants transact with the fund, an ETF is more likely to redeem in kind 

(that is, by delivering certain assets from the ETF’s portfolio, rather than in cash), thereby 

avoiding the need for the ETF to sell assets to meet redemptions.  

Additional Identifying Information 

 
73  See Item B.1.d of proposed Form N-PORT. To identify the ETF share class, funds would be required to 

report the ticker symbol of the ETF share class. 
74  See Item B.6.d of proposed Form N-PORT. 



54 
 

While registered funds are currently required to report certain identifying information on 

Form N-PORT, we are proposing to require funds to provide ticker symbols by registrant, and 

for each class of a registrant or series, as applicable, as well as certain other class-level 

information, if any, to help staff and data users use data more efficiently.75 We recognize that 

when the Commission adopted Form N-PORT, the Commission determined that requiring a 

registered fund to report ticker symbols on Form N-PORT would not be necessary because other 

reported information (e.g., for the registrant, information such as the name, CIK, and LEI; and 

for the series, information such as the name, EDGAR identifier, and LEI) was sufficient for 

Commission staff, as the primary user of Form N-PORT, to identify funds filing reports on Form 

N-PORT, and could also be useful for investors and other potential users.76 However, since then, 

with experience, the staff has found that ticker symbols would enhance the efficiency of data 

analysis.  

For example, staff has observed that matching a registered fund, series, and/or class using 

only its name in multiple data sources (e.g., Form N-PORT reports, other reports such as Form 

N-CEN, and third-party vendor information) can be difficult because of very slight differences in 

the reported name of the fund, series, and/or class. Further, staff has observed that ticker symbols 

are more widely used than LEIs across multiple data sources, and that while LEIs are not 

assigned on the basis of share classes, there are distinct ticker symbols identifying each fund 

share class. Requiring a registered fund to report a ticker symbol associated with the registrant, 

or for each class of the registrant or series, as relevant, would facilitate the ability of the data user 

to conduct comprehensive data analyses across multiple data sources more efficiently, and would 

 
75  See Item A.3 of proposed Form N-PORT. 
76  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.69. 



55 
 

complement other identifying information that registered funds currently report across other 

reporting forms.77  

We request comment on the proposed amendments to Form N-PORT, including the 

following:  

24. Should we, as proposed, relating to portfolio level risk metrics, increase the 

threshold for determining which registered funds must report risk metrics from 

25% or more of the fund’s net asset value to 50% or more of the fund’s net asset 

value? Should the threshold be lower (e.g., 30% or 40%) or higher (e.g., 60% or 

70%)? In addition to, or separate from, the numerical threshold, should we change 

the period over which the threshold is measured? For instance, instead of 

measuring the average value of the fund’s debt positions for the previous 3 

months, should the period be shorter or longer, such as 1-, 6-, or 12-months? Are 

there other threshold alternatives that would be more effective or appropriate? 

25. Should we, as proposed, remove the requirement to report the DV01 interest rate 

risk metric? Do investors or other members of the public use this information? If 

so, how? Do the benefits of this information to investors or other members of the 

public justify the costs of reporting it? 

26. Should we, as proposed, simplify the reporting of the DV100 interest rate risk 

metric by requiring registered funds to report an aggregate figure across all 

currencies for which the fund had a value of 1% or more of its net asset value, 

 
77  Registered funds currently are required to provide their ticker symbols in other filings with the 

Commission. See, e.g., Item 1 of Form N-1A and Item C.2 of Form N-CEN. By requiring current ticker 
symbol information on Form N-PORT, the proposed amendments would address situations where a 
registered fund, for example, may have changed its ticker symbol information between the fund’s annual 
filings on Form N-CEN and, thus, the ticker information in the fund’s most recent Form N-CEN filing is 
inaccurate. 



56 
 

rather than separately by currency? What effect, if any, would this change have on 

the use of Form N-PORT information by investors or other members of the 

public? In addition to, or separate from these proposed changes, should we 

eliminate the need to report DV100 separately for different maturity buckets (3 

months, 1 year, 5 years, 10 years, and 30 years) and instead require a single 

aggregated DV100 measure? 

27. Should we, as proposed, simplify the reporting of the credit spread risk metrics by 

no longer requiring registered funds to provide separate measures for investment 

grade and non-investment grade exposures? What effect, if any, would this 

change have on the use of Form N-PORT information by investors or other 

members of the public? In addition to, or separate from these proposed changes, 

should we eliminate the requirement to report credit spread risk metrics separately 

for different maturity buckets (3 months, 1 year, 5 years, 10 years, and 30 years) 

and instead require a single aggregated credit spread risk measure? 

28. What is the burden associated with the proposed changes to portfolio level risk 

metrics? How would the reporting burden compare between the current and 

proposed requirements?  

29. Should we, as proposed, require multiple class funds to report returns only for a 

single representative class? Is the proposed method of selecting a representative 

class effective? Should we instead define a representative class as the class with 

the greatest net assets as of the end of the reporting period or give a registered 

fund full discretion to choose a representative class based on considerations such 

as age or size of the class (e.g., by selecting the oldest class or the class with the 



57 
 

greatest net assets), without considering which class has the longest period of 

returns as Form N-1A requires under certain circumstances? How often would the 

representative class change under our proposed approach or potential alternatives? 

Are there other criteria a fund should be permitted or required to use to select its 

representative class? Would the proposed approach of requiring reporting of only 

a single representative class affect how investors or other users of Form N-PORT 

use the reported information? If so, could investors or other users instead use 

return information in fund prospectuses or shareholder reports for individual 

classes? 

30. Should we, as proposed, continue to require registered funds to report monthly net 

realized gain (loss) and net change in unrealized appreciation (or depreciation) 

attributable to derivatives for the listed asset categories (commodity contracts, 

credit contracts, equity contracts, foreign exchange contracts, interest rate 

contracts, and other contracts)? Should we make any changes to the listed asset 

categories? Should we require the aggregate net realized gain (loss) and net 

change in unrealized appreciation (depreciation) for all derivatives positions, 

instead of requiring separate figures for each asset category? 

31. As proposed, should we remove the requirement to report monthly net realized 

gain (loss) and net change in unrealized appreciation (or depreciation) by 

derivative type (forward, future, option, swaption, swap, warrant, and other) 

within each asset category of derivatives? Would removal of this information 

reduce reporting burdens for registered funds? Would removal of this information 

affect investors or other users of Form N-PORT information and, if so, how? 



58 
 

32. Currently, Form N-PORT requires funds to report the notional value for most 

types of derivatives but, for options, requires funds to report the exercise price.78 

In addition, funds must calculate the notional value of derivatives positions for 

purposes of meeting other regulatory requirements.79 When reporting options 

positions on Form N-PORT, should we require registered funds to provide the 

notional value, rather than the exercise price? Would this change streamline 

reporting and reduce reporting burdens (and, if so, by how much)? What effect, if 

any, would such a change have on the public’s use of Form N-PORT information? 

33. Should we, as proposed, eliminate the names rule-related reporting? Do enhanced 

disclosures in fund prospectuses about a fund’s 80% investment policy, along 

with available information about fund portfolio holdings, provide the public with 

sufficient information to understand a fund’s investments and risks? To what 

extent would removing the names rule-related reporting reduce reporting burdens 

for registered funds? Instead of eliminating the names rule-related reporting, are 

there modifications to these requirements we should make? For example, should 

we require a fund to report the value of the fund’s 80% basket, as a percentage of 

the value of the fund’s assets, but remove other names rule-related reporting 

requirements? 

34. Should we, as proposed, eliminate reporting of the payoff profiles of non-

derivatives? Should we, as proposed, eliminate reporting of the conversion ratio 

 
78  See Item C.11.c.v of current Form N-PORT. 
79  17 CFR 270.18f-4 (defining derivatives exposure as the sum of the gross notional amount of the fund’s 

derivatives transactions); Item B.3 of Form N-PORT (requiring funds to use the notional value of certain 
derivatives for which the underlying reference asset or assets are debt securities or an interest rate when 
determining if the fund is required to report portfolio level risk metrics due to the value of its exposure to 
debt instruments). 



59 
 

and delta of convertible debt securities? Would removal of the conversion ratio of 

convertible debt securities affect investors or other uses of Form N-PORT 

information and, if so, how? Should we, as proposed, eliminate reporting of the 

reason an open-end fund has reported multiple liquidity classifications for a single 

investment? What are the burdens of reporting each of the items that we propose 

to eliminate, and how much burden would be eliminated by the proposed 

changes? Are there items that we are proposing to eliminate that we should retain 

and/or modify? If so, what are they, why should we retain or modify them, and 

what should any modifications be?  

35. What is the impact to the public if there is less Form N-PORT data available 

because of these proposed amendments to the form? Please provide examples. 

36. Should we, as proposed, require registered funds with ETF share classes to 

disclose net assets and flows for these share classes separately from information 

for the full fund? Should we amend Form N-PORT to require more or less 

information about ETF share classes? If there is other information that would be 

helpful to the public, provide specific examples of how that information would be 

useful. 

37. Should we, as proposed, require registered funds to provide ticker information by 

registrant or for each class of a registrant or series, as applicable? Should we, as 

proposed, require registered funds to report for any classes of the registrant or 

series the class name and EDGAR class identification number as identifying 

information in Part A? How would the reporting burden compare between the 

current and proposed requirements?  



60 
 

38. Should the Commission eliminate reporting on Form N-PORT related to the 

liquidity of a fund’s investments and, if so, why?80 

39. Are there other Form N-PORT items that we should modify or eliminate? Why 

are the benefits of the reported information to the Commission and the public not 

justified by the costs of reporting the information? 

D. Proposed Transition Period 

We propose to provide a tiered transition period for registered funds to comply with the 

proposed amendments, if adopted, based on fund size. We propose to provide a 12-month 

transition period for larger entities and an 18-month transition period for smaller entities. For 

these purposes, larger entities would be registered funds that, together with other investment 

companies in the same “family of investment companies” (as such term is defined in Item B.5 of 

Form N-CEN), have net assets of $10 billion or more as of the end of the most recent fiscal year. 

Smaller entities would be registered funds that, together with other investment companies in the 

same family of investment companies, have net assets of less than $10 billion as of the end of the 

most recent fiscal year.81 The tiered transition period would provide time for registered funds to 

 
80  See Items B.7 (requiring information related to a fund’s highly liquid investment minimum, if applicable), 

B.8 (requiring information about the percentage of a fund’s highly liquid investments that it has pledged as 
margin or collateral in connection with derivatives transactions classified in non-highly liquid categories), 
and C.7 (requiring the liquidity classification of each portfolio investment) of Form N-PORT. 

81  For the last several years, the Commission generally has used a threshold of $1 billion in net assets for 
differentiating between larger and smaller registered investment companies when providing smaller entities 
with additional time to comply with new requirements. We instead are proposing to use a $10 billion 
threshold for the transition period, based on an analysis of the distribution of assets across funds at different 
net asset thresholds. This $10 billion threshold is designed to be a reasonable means of distinguishing larger 
and smaller entities for purposes of tiered compliance dates for Form N-PORT reporting requirements. We 
estimate that, as of Dec. 2024, 22.9% of registered investment companies would be considered to be 
smaller entities. These smaller entities hold approximately 2.13% of aggregate assets of registered 
investment companies. These estimates are based on data reported on Form N-CEN through Jan. 21, 2025. 
The Commission also recently proposed similar amendments to how it defines “small entity” under the 
Regulatory Flexibility Act for investment companies. See Amendments to the “Small Business” and “Small 
Organization” Definitions for Investment Companies and Investment Advisers for Purposes of the 
Regulatory Flexibility Act, Investment Company Act Release No. 35864 (Jan. 7, 2026) [91 FR 1107 (Jan. 
12, 2026)] (“Small Entity Proposing Release”).61 
 

adjust their internal processes and arrangements with service providers to begin to file Form N-

PORT reports on a monthly basis within 45 days of month end and to modify the information 

that is reported. Registered funds would not need to make adjustments related to publication 

frequency because the proposed amendments align with historic requirements, and the 2024 

amendments have not yet gone into effect.  

At the end of the relevant transition period, registered funds would be required to shift 

from a quarterly filing approach to a monthly filing approach and file reports that conform to the 

amended information requirements.82 We propose to require registered funds to make their first 

monthly filing for the first month of the fiscal quarter that begins after the compliance date. 

Because fiscal quarter ends differ among funds, this approach would result in funds being 

required to file their first monthly reports at different times within a three-month range, 

depending on the date of a fund’s fiscal quarter end. Basing the approach on fiscal quarter end is 

meant to ease the transition from quarterly to monthly filing, as this approach would avoid 

requiring some registered funds to begin to file monthly Form N-PORT reports in the middle of a 

fiscal quarter. As an illustrative example, if the compliance date were in May of a given year, the 

transition period would operate as shown in Table 3. 

Table 3. Illustrative Example of Proposed Transition from Quarterly to Monthly Filings 

with a Hypothetical Compliance Period End in May 

Fund’s Fiscal 
Quarter End 

Last Quarterly Filing First Monthly Filing 

May Filing covering the months of 
March, April, and May would be 

Filing for June would be due within 
45 days of the end of June 

 
82  Once a registered fund shifts from quarterly filing to monthly filing, the fund would also no longer be 

required to maintain records of Form N-PORT information no later than 30 days after the end of each 
month under rule 30b1-9. If the proposal is adopted, we anticipate that registered funds would be required 
to maintain records under that rule until they begin to file reports on a monthly basis, consistent with the 
approach taken in the 2024 amendments. See 2024 Adopting Release, supra note 1, at n.170 and 
accompanying text.  



62 
 

due within 60 days of the end of 
May 

June Filing covering the months of April, 
May, and June would be due within 
60 days of the end of June 

Filing for July would be due 45 
days after the end of July 

July Filing covering the months of May, 
June, and July would be due within 
60 days of the end of July 

Filing for August would be due 
within 45 days of the end of August 

 

In addition, we propose to amend the effective and compliance dates of the Form N-

PORT amendments in the 2024 Adopting Release that would not be superseded by this 

rulemaking to align with the effective and compliance dates for the proposed amendments in this 

release, if adopted. This would include the amendments to entity identifiers to separate the 

concepts of LEI and RSSD ID, as well as technical amendment to the definition of ETF in Form 

N-PORT to include a direct reference to 17 CFR 270.6c-11, the Commission’s exemptive rule 

for ETFs.  

We request comment on the proposed transition period: 

40. Would the proposed transition period provide registered funds enough time to comply 

with the proposed amendments? Should the period be shorter or longer? 

41. Should the transition period differ by fund size, as proposed, or should the transition 

period be the same for all registered funds? Is there a different approach we should 

use for determining fund size for purposes of the transition period? 

42. As proposed, should we change the compliance date for the amendments from the 

2024 Adopting Release that are not being superseded (e.g., the amendments to 

separate the concepts of LEI and RSSD ID) to align with the compliance date for the 

proposed amendments? If the transition period for the 2024 amendments that are not 

being superseded should differ, in what way should it differ? 



63 
 

43. Is the proposed approach for transitioning from quarterly filing to monthly filing 

workable? Would a different approach be more effective? For example, should we 

instead require registered funds to make their first monthly filing for the first month 

preceding the end of the compliance period, meaning registered funds would begin to 

file monthly reports at the same time, regardless of their fiscal year ends? Under this 

approach, if that month is not the beginning of a fund’s fiscal quarter, should we 

require the fund to file information for prior months in that fiscal quarter at the same 

time the first monthly report is due? 

III. Economic Analysis 

A. Introduction 

Reports on Form N-PORT are an important source of information for the Commission 

and its staff. This information helps the Commission monitor industry trends, identify risks, 

inform policy and rulemaking, and assists the staff in examination and enforcement efforts, 

which ultimately benefits investors. In addition, investors and other market participants also 

benefit from the publicly available information that registered funds report on Form N-PORT 

because it aids them in making more informed investment decisions. Currently, the Commission 

receives reports on Form N-PORT on a quarterly basis, no later than 60 days after the end of a 

registered fund’s fiscal quarter, with each quarterly report containing month-end information for 

each month in the quarter, while investors have access to Form N-PORT portfolio data for only 

the third month of a fund’s fiscal quarter.83  

 
83  Monthly portfolio holdings of certain open-end and closed-end funds may also be available on funds’ 

websites, as well as for a fee through third-party data aggregators. Voluntary disclosures of monthly 
portfolio holdings that are currently publicly available may be inconsistent across registered funds and over 
time and may vary in format, presentation, or ease of access. 



64 
 

In 2024, the Commission adopted amendments to Form N-PORT that were intended to 

give the Commission timelier information to conduct comprehensive oversight of the registered 

fund industry, as well as to give investors information to make more informed investment 

decisions.84 Specifically, the 2024 amendments require registered funds to file monthly reports 

within 30 days of month end, replacing the prior approach requiring these funds to file reports 

for each month in a fund’s fiscal quarter no later than 60 days after the end of each fiscal quarter. 

In addition, the 2024 amendments make monthly report information publicly available 60 days 

after month end, which replaces the prior approach of making information for only the third 

month of the fiscal quarter public. The 2024 amendments have yet to be implemented. 

Following adoption of the Form N-PORT amendments, several developments caused the 

Commission to delay the effective and compliance dates of the 2024 amendments and review 

their potential effects.85 As a result of this review, we are proposing to extend the filing deadline 

to 45 days after month end to reduce the costs to registered funds of filing Form N-PORT while 

continuing to provide the Commission with timely data. We are also proposing to publish reports 

for only the third month of a registered fund’s fiscal quarter 60 days after month end to reduce 

the risks to funds and their investors of publishing significantly more information on funds’ 

holdings. In addition, we are proposing to remove or streamline certain items and sub-items of 

the form and to modernize the form to better account for fund structures with ETF share classes. 

The Commission has considered the economic effects of the proposed amendments.86 

Where possible, we have attempted to quantify the economic effects. In some cases, however, we 

 
84  See supra note 1. 
85  See supra section I.A. 
86  Section 2(c) of the Act and section 3(f) of the Exchange Act direct the Commission, when engaging in 

rulemaking where it is required to consider or determine whether an action is necessary or appropriate in, 
 



65 
 

are unable to quantify the economic effects because we lack the information necessary to provide 

a reasonable and reliable numerical estimate. For example, relative to the 2024 amendments, the 

proposed amendments would reduce the amount of information investors have to compare 

registered funds by reverting the frequency of Form N-PORT publication to prior standards. For 

the same reasons we were unable to quantify some of the economic effects associated with the 

increase in publication frequency associated with the 2024 amendments, we are unable to 

quantify these effects as we revert to prior standards in this proposal.87 As described more fully 

below, the Commission is providing both a qualitative assessment and quantified estimate of the 

economic effects, where feasible. 

We request comment on all aspects of the economic analysis of the proposed 

amendments. To the extent possible, we request that commenters provide supporting data and 

analysis on the benefits, costs, and effects on competition, efficiency, and capital formation of 

the proposed amendments or any reasonable alternatives. 

B. Baseline 

The baseline against which the costs, benefits, and the effects on efficiency, competition, 

and capital formation of the proposed rules are measured consists of the current state of the 

 
or consistent with, the public interest, to consider, in addition to the protection of investors, whether the 
action will promote efficiency, competition, and capital formation. In addition, section 23(a)(2) of the 
Exchange Act requires the Commission, when making rules under the Exchange Act, to consider among 
other matters the impact that the rules would have on competition and prohibits the Commission from 
adopting any rule that would impose a burden on competition not necessary or appropriate in furtherance of 
the purposes of the Exchange Act. The analysis below addresses the likely economic effects of the 
amendments, including the anticipated benefits and costs of the amendments and their likely effects on 
efficiency, competition, and capital formation. The Commission also discusses the potential economic 
effects of certain alternatives to the approaches taken in this release. 

87  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.180. 



66 
 

securities markets and the current regulatory framework with respect to registered management 

investment companies and ETFs organized as unit investment trusts (“registered funds”).88 

1. Regulatory Baseline 

Registered funds are required to file periodic reports on Form N-PORT about their 

portfolios and each of their portfolio holdings as of month end. In addition to providing a 

registered fund’s portfolio holdings, Form N-PORT reports also provide information to help 

assess a fund’s risk and return characteristics, such as portfolio level risk metrics, liquidity 

related information, and monthly fund returns for each fund share class.89 Additional 

amendments to Form N-PORT were also adopted in 2023 that would require certain registered 

funds to report information related to their compliance with the names rule after that rule’s 

compliance date.90  

Until the 2024 amendments go into effect, registered funds will continue to file these 

reports on a quarterly basis, with each report due 60 days after the end of a fund’s fiscal quarter. 

While each report includes month-end portfolio information for each month in the relevant fiscal 

quarter, only information about portfolio holdings for the third month of each fiscal quarter is 

made available to the public upon filing; information for the first and second month of each 

 
88  See, e.g., Nasdaq v. SEC, 34 F.4th 1105, 1111–15 (D.C. Cir. 2022). This approach also follows SEC staff 

guidance on economic analysis for rulemaking. See SEC Staff, Current Guidance on Economic Analysis in 
SEC Rulemaking (Mar. 16, 2012), available at https://www.sec.gov/divisions/riskfin/ 
rsfi_guidance_econ_analy_secrulemaking.pdf (“The economic consequences of proposed rules (potential 
costs and benefits including effects on efficiency, competition, and capital formation) should be measured 
against a baseline, which is the best assessment of how the world would look in the absence of the 
proposed action.”); id. at 7 (“The baseline includes both the economic attributes of the relevant market and 
the existing regulatory structure.”).  

89  While the proposed amendments to Form N-PORT would require sales loads and redemption fees to be 
deducted from monthly fund return calculations, some registered funds currently exclude these fees from 
their monthly fund returns on Form N-PORT. This approach is consistent with many funds’ current 
practices and consistent with prior staff guidance. See supra section II.C. 

90  See Names Rule Adopting Release, supra note 10. 



67 
 

fiscal quarter remains confidential. Registered funds are also currently required to maintain the 

data Form N-PORT requires within 30 days of a month end for recordkeeping purposes until the 

2024 amendments go into effect.91  

The 2024 amendments require registered funds to file monthly reports within 30 days of 

month end and the Commission would publish those reports 60 days after month end. The 

subsequent delay of the effective and compliance dates for the 2024 amendments means that 

larger entities must comply with these new requirements as of November 17, 2027, and that 

smaller entities must comply by May 18, 2028. 

Currently, a registered fund may report certain portfolio holdings as miscellaneous 

securities, meaning that information about these holdings can remain nonpublic for up to a year, 

provided that the combined value of the positions reported as miscellaneous securities does not 

exceed 5% of the total value of a fund’s investments and that these positions have not been 

previously disclosed to the public.  

Part F of Form N-PORT also currently requires a registered fund to attach a complete 

schedule of portfolio holdings for the end of the first and third quarters of the fund’s fiscal year, 

presented in accordance with Regulation S-X, within 60 days after the end of the reporting 

period. Further, ETFs, including actively managed ETFs, generally are required to provide full 

portfolio holdings on their websites every business day.92 A small number of “non-transparent” 

ETFs have received exemptive orders from the Commission permitting them not to disclose their 

portfolio holdings on a daily basis. Monthly portfolio holdings of certain registered funds may 

also be available on their websites, as well as through third-party data aggregators (typically for a 

 
91  See rule 30b1-9.  
92  See rule 6c-11(c)(1)(i).  



68 
 

fee), generally on a lagged basis (e.g., 15, 30, 45, or more days after a month end). However, this 

more frequent publication and/or aggregation by third parties of portfolio data is voluntary. 

Currently, most ETFs are structured as individual funds. However, since the early 2000s, 

there have been some mutual funds with ETF share classes. In recent years, the Commission has 

received requests to provide exemptive relief to allow additional mutual funds with ETF share 

classes and the Commission recently began granting exemptive relief.93  

2. Affected Entities 

The proposed amendments to the filing and public disclosure frequency of Form N-

PORT reports would affect all registered funds that are currently required to file reports on Form 

N-PORT. Table 4 below lists registered fund counts along with their net assets by type.94 

 
93  See supra note 72. 
94  Form N-CEN provides census-type information about registered funds, while Form N-PORT provides 

detailed information about fund activities. Because Form N-PORT does not include information about fund 
types, we use information reported on Form N-CEN to estimate the number of affected funds for each type 
of fund. We use information reported to the Commission for each fund as of Dec. 31, 2024, incorporating 
filings and amendments to filings received through May 15, 2025. Net assets are monthly average net 
assets during the reporting period identified on Item C.19.a of Form N-CEN and validated with Bloomberg 
(for ETFs). Current values are based on the most recent filings and amendments, which are based on fiscal 
years and are therefore not synchronous. Submissions of Form N-CEN reports are required on a yearly 
basis. Therefore, these estimates do not include newly established funds that have not completed their first 
fiscal year and, therefore, have not filed on Form N-CEN yet. These estimates also do not account for the 
funds that have been terminated since the last Form N-CEN report was filed. Therefore, the estimates for 
the number of registered funds and their net assets may be over- or under-estimated. 



69 
 

Table 4. Registered Funds Required to File Form N-PORT by Type, as of December 31, 

2024 

Registered Fund Type 
TOTAL 

Number 
Net assets, $ 

trillion 
1. Open-end funds registered on Form N-1A:     
-- a. Mutual funds required to file Form N-PORT1 8,497   $  23.10  
-- b. ETFs:2 3,481   $    7.34 
----- i. non-transparent ETFs3 42 $    0.01 
----- ii. daily website disclosure required4 3,439   $    7.33 
2. Closed-end funds registered on Form N-25 671   $    0.37  
3. ETFs that are UITs registered on Form N-8B-26 4   $    1.00  
4. Variable annuity separate accounts registered on 
Form N-37 15 $    0.27 
Total 12,668 $  32.08 
Notes: 

1. Mutual funds are identified as those funds reported in Item B.6.a of Form N-CEN that are not identified as 
ETFs in Item C.3.a.i of Form N-CEN. Money market funds are excluded from the number of mutual funds, as 
they are not required to file Form N-PORT. We use information reported in Item C.3.g of Form N-CEN to 
identify money market funds and exclude 307 money market funds that hold approximately $6.86 trillion in 
net assets from the total number of mutual funds in order to estimate the number of mutual funds required to 
file Form N-PORT. 

2. ETFs registered as open-ended funds are identified in Item C.3.a.i of Form N-CEN. UIT ETFs and 
exchange-traded managed funds are excluded from these ETF totals and presented in a separate line item. 

3. Non-transparent ETFs are not subject to daily website disclosure of their portfolio holdings. The estimate 
for the number of non-transparent ETFs is based on the staff analysis of funds that have been granted 
exemptive relief to operate actively managed ETFs that do not provide daily portfolio transparency (non-
transparent ETFs). 

4. ETFs identified in Item C.3.a.i of Form N-CEN excluding 42 non-transparent ETFs.  

5. Closed-end funds are identified in Form N-CEN, Item B.6.b. 

6. UIT ETFs are identified in Form N-CEN Item B.6.g, and are also reported in Item E of Form N-CEN. 

7. Variable annuity separate accounts are identified in Form N-CEN, Item B.6.c. 
 

We estimate that there are 12,668 registered funds currently required to file reports on 

Form N-PORT that hold approximately $32.08 trillion in assets (approximately 82% of total 

registered investment companies’ assets). Different types of registered funds may be affected 

differently by the amendments to Form N-PORT. Among the affected funds, there are 8,497 



70 
 

mutual funds that represent approximately 72% of registered funds’ assets, 3,481 ETFs 

registered as open-end funds that represent approximately 23% of registered funds’ assets, 671 

closed-end funds that represent approximately 1.2% of registered funds’ assets, 4 ETFs 

registered as unit investment trusts that represent approximately 3.1% of assets of all registered 

funds, and 15 variable annuity separate accounts that represent approximately 0.8% of assets of 

all registered funds. Among the ETFs registered as open-end funds, 42 are non-transparent ETFs 

with assets of $0.01 trillion and 3,439 are ETFs for which daily website portfolio disclosure is 

required, with assets of $7.33 trillion. 

Of the 12,668 funds required to file reports on Form N-PORT, some registered funds will 

be affected more than others by the proposed amendments to Form N-PORT intended to refine 

the information funds provide.95 30.6% of registered funds representing 25.4% of aggregate net 

assets of N-PORT filers currently report portfolio level risk metrics on Item B.3, while 28.1% of 

registered funds representing 22.5% of aggregate net assets of N-PORT filers have an average 

value of debt securities for the three months prior to December 31, 2024 that exceeds 50% of 

each fund’s net asset value. 47.5% of registered funds representing 62.9% of aggregate net assets 

of N-PORT filers report monthly fund returns for more than one share class on Item B.5.a. 

44.1% of registered funds representing 63.7% of aggregate net assets of N-PORT filers report 

unrealized appreciation (or depreciation) attributable to derivatives in Item B.5.c. All 12,668 

registered funds are required to report payoff profile information for non-derivative positions in 

Item C.3. 0.3% of registered funds representing 1.1% of aggregate net assets of N-PORT filers 

attribute multiple liquidity classification categories to a holding in Item C.7. 5.5% of registered 

 
95  To obtain the percentage of registered funds affected by each Form N-PORT item that follows, we use 

information reported to the Commission on Form N-PORT for each registered fund as of Dec. 31, 2024, 
incorporating filings and amendments to filings received through May 15, 2025. 



71 
 

funds representing 7.8% of aggregate net assets of N-PORT filers report information on 

convertible debt securities in Item C.9.f. Approximately 9,628 registered funds representing 76% 

of registered funds’ assets would be subject to reporting requirements related to their compliance 

with the names rule in Item B.11 and Item C.2.e, once that rule’s compliance period ends.96 

Finally, 69 mutual funds offer an ETF share class, representing 18.9% of aggregate net assets of 

open-end Form N-PORT filers.97 

Table 5 below lists registered fund counts along with their aggregate net assets by fiscal 

year end.98 Among registered funds, there is variation in the fiscal year end. The most common 

fiscal year end used by registered funds is December (26.9% of registered funds), the second 

most common fiscal year end is October (19.0% of registered funds), and August is the third 

most common fiscal year end (8.8% of registered funds).  

Table 5. Registered Funds by Fiscal Year End, as of Dec. 31, 2024 

Fiscal Year End 
Number of Registered 

Funds Net Assets 
# % of total $, trillion % of total 

31-Jan        197  1.5%  $           0.61 1.7% 
28-Feb        398  3.1%  $           2.22  6.1% 
31-Mar     1,116  8.7%  $           3.37  9.3% 
30-Apr        529  4.1%  $           0.99  2.7% 

 
96  See Names Rule Adopting Release, supra note 10, at n.495 and accompanying text. The Commission 

estimated that the names rule would increase the percentage of funds subject to the names rule from 60% to 
76%. We therefore estimate that 9,628 = 76% * 12,668 funds would be affected by the proposed removal of 
Items B.11 and C.2.e on Form N-PORT. 

97  This figure does not reflect recent exemptions, issued by the Commission, permitting additional mutual 
funds to add ETF share classes. See, e.g., DFA Investment Dimensions Group Inc., Investment Company 
Act Release Nos. 35770 (Sept. 29, 2025) (notice) and 35786 (Nov. 17, 2025) (order). 

98  We use information reported on Form N-PORT to the Commission for each registered fund as of Dec. 31, 
2024, incorporating filings and amendments to filings received through May 15, 2025. Fiscal year is 
reported in Item A.3.a of Form N-PORT. Net assets are reported in Item B.1.c of Form N-PORT. We note 
that the total number of the registered funds in this table (12,898 funds) differs from the number based on 
the Form N-CEN data in Table 4 (12,668 funds) because Form N-PORT is submitted on a less delayed 
basis compared to Form N-CEN; thus, it may include newly established funds that have not completed their 
first fiscal year and, therefore, have not filed Form N-CEN yet, as well as funds that have been terminated 
since the last Form N-CEN was filed.  



72 
 

31-May        626  4.9%  $           1.26  3.5% 
30-Jun        816 6.3%  $           1.46  4.0% 
31-Jul        672  5.2%  $           1.28  3.5% 

31-Aug     1,131  8.8%  $           2.78  7.7% 
30-Sep     1,112  8.6%  $           4.03  11.1% 
31-Oct     2,448  19.0%  $           5.89  16.2% 

30-Nov        389  3.0%  $           0.88  2.4% 
31-Dec     3,464  26.9%  $           11.46  31.6% 

TOTAL   12,898  100.0%  $         36.23  100.0% 
 

3. Economic Literature on the Disclosure of Registered Fund Portfolio Holdings 

This section summarizes the academic literature pertaining to the economic effects 

relevant to the changes we are proposing. The Commission has also considered the potential 

economic effects of publicly disclosing registered fund portfolio information in several past 

releases.99 

One strand of the academic literature suggests that the disclosure of holdings can have 

negative economic consequences for a registered fund and its investors. One early study provides 

a theoretical framework showing that, under certain assumptions, “predatory trading” can 

increase trading costs for a large institution (e.g., a fund) when it needs to liquidate a position 

that is known by other market participants.100 Subsequent studies claim that strategies that 

anticipate the sales of mutual funds based on their holdings and predicted outflows, trading 

ahead of them (“front running”), earn excess returns, suggesting that funds incur additional costs 

as a result of these disclosures.101 Several studies also suggest that market participants can “free-

 
99  See supra notes 1, 2, and 20. Those releases also include reviews of the associated academic literature.  
100  See Markus K. Brunnermeier & Lasse Heje Pedersen, Predatory Trading, 60 J. OF FIN. 1825, no.4, 

(2005). 
101  See, e.g., Joshua Coval & Erik Stafford, Asset Fire Sales (and Purchases) in Equity Markets, 86 J. OF FIN. 

ECON.479 (2007); Teodar Dyakov& Marno Verbeek, Front Running of Mutual Fund Fire-Sales (Sept. 6, 
2012) (revised May 1, 2014), 37 J. OF BANKING AND FIN., no.12, 2013 at 4931-4942, available at 
https://ssrn.com/abstract=2170660 retrieved from SSRN Elsevier database. See, also, Sophie Shive & 
Hayong Yun, Are Mutual Funds Sitting Ducks?, 107 J. OF FIN. ECON. 220 (2013). 

https://ssrn.com/abstract=2170660


73 
 

ride” on registered funds by “copycatting” their strategies, earning excess returns without 

incurring the information production costs of the target fund.102 Another study more generally 

finds that while portfolio holdings disclosure by registered funds has beneficial effects, such as 

increased market liquidity, it reduces the returns of otherwise informed funds, noting that such 

costs reduce a fund’s incentive to perform costly research on the securities they invest in.103   

Other studies examine the effect of disclosure on registered fund manager behavior and 

potential agency problems between a fund manager and fund investors. One study suggests that 

more standardized portfolio disclosures can decrease agency problems between funds and 

investors.104 In contrast, another study suggests that more frequent disclosure actually increases 

window-dressing by low-skill fund managers, who try to obfuscate poor performance by 

manipulating their holdings around reporting dates, though more frequent disclosure allows 

investors to sort out skilled from unskilled managers more rapidly.105 

Some studies analyze the effects of portfolio disclosures on issues related to market 

efficiency and capital formation. As noted above, one study suggests that while disclosure is 

 
102  See Mary Margaret Frank, et al., Copycat Funds: Information Disclosure Regulation and the Returns to 

Active Management in the Mutual Fund Industry, 47 J. OF LAW AND ECON., no. 2, 2004 at 515-541; Marno 
Verbeek & Yu Wang, Better Than the Original? The Relative Success of Copycat Funds, 37 J. OF BANKING 
AND FIN. 3454 (2013). 

103  See Vikas Agarwal, et al., Mandatory Portfolio Disclosure, Stock Liquidity, and Mutual Fund 
Performance, 76 J. OF FIN. 2773-2776, (2015) (“Agarwal et al.”). 

104  See Ki-Soon Choi, The Role of Portfolio Disclosures in Mutual Funds (working paper revised Aug. 2 
2023), available at SSRN: https://ssrn.com/abstract=4283140 (retrieved from SSRN Elsevier database). 
The paper analyzes the 2016 adoption of Form N-PORT reporting requirements and suggests that 
standardized portfolio disclosures decreased information asymmetry between fund investors and managers, 
showing that, as a result of the 2016 reporting requirements, fixed-income fund managers (who generally 
have incentives to display lower volatility) became less likely to engage in return smoothing, and equity 
managers became less likely to engage in risk shifting (increasing the risk of a fund portfolio in hopes of 
achieving higher portfolio returns). 

105  See Xiangang Xin, et al., Wrong Kind of Transparency? Mutual Funds’ Higher Reporting Frequency, 
Window Dressing, and Performance, 62 J. ACCT. RSCH.737 (2024); See also Vikas Agarwal, et al., Window 
Dressing in Mutual Funds, 27 REV. OF FIN. STUD, 3133 (2024) for a theoretical model of why managers 
engage in window dressing. 



74 
 

costly for individual funds, it can increase the liquidity of the underlying market for a fund’s 

securities, implying lower trading costs for investors and a lower cost-of-capital for issuing 

firms.106 Another study suggests that quarterly holdings disclosure requirements cause funds to 

alter their trading strategies to conceal their intentions leading up to reporting dates, reducing 

price efficiency around these dates.107 Finally, another study suggests that increased portfolio 

holding disclosure requirements can disincentivize a fund from performing costly research 

activities, reducing price informativeness for firms that the fund invests in and decreasing the 

ability of those firms’ managers to learn from market prices when making real investment 

decisions.108   

C. Benefits and Costs of the Amendments 

1. Filing Timeframe 

We are proposing to amend rule 30b1-9 and Form N-PORT to require registered funds to 

file Form N-PORT reports within 45 days after the end of the month to which they relate.109 

Specifically, rather than filing monthly reports with the Commission within 30 days after the end 

of each calendar month as finalized in the 2024 Adopting Release, we are proposing to require 

registered funds to file reports on a monthly basis due within 45 days after the end of the month 

to which they relate. As a result, the proposed approach would provide registered funds with 

more time to gather and verify the information required to be filed on Form N-PORT and to 

submit the filing. 

 
106  See Agarwal et al., supra note 103. 
107  See Todd A. Gormley, et al., More Informative Disclosures, Less Informative Prices? Portfolio and Price 

Formation Around Quarter-Ends, 146 J. OF FIN. ECON. 665 (2022). 
108  See Jalal Sani, et al., Spillover Effects of Mandatory Portfolio Disclosures on Corporate Investment, 76 J. 

OF ACCT. & ECON. 101641 (2023).  
109  See supra note 11. 



75 
 

The primary benefit of the revised 45-day filing deadline would be to reduce the costs 

that funds might otherwise incur in gathering, verifying, and ultimately filing Form N-PORT on 

a monthly basis under the 2024 amendments. The associated cost savings may be passed on to 

fund investors. While funds will still incur costs associated with gathering and reviewing Form 

N-PORT information, the additional 15 days they have to do so might reduce, for example, the 

number of personnel some funds require. Similarly, while funds will still incur costs associated 

with data validation and data tagging, third-party service provider fees, personnel costs, and 

internal costs associated with developing and maintaining systems, processes, and procedures to 

file form N-PORT on a monthly basis,110 the additional 15 days may reduce the number of 

personnel required to file Form N-PORT each month for some funds. The 45-day filing deadline 

would also reduce any potential costs associated with increased errors and resubmissions under a 

30-day filing deadline.111 The 2024 Adopting Release also stated that some registered funds, 

such as those belonging to smaller fund groups that may not experience economies of scale, may 

experience higher costs associated with a 30-day filing deadline. Consistent with this analysis, 

we would expect that cost reductions associated with the proposed 45-day filing deadline to 

particularly benefit such funds. Finally, during staff outreach following the 2024 Adopting 

Release, industry participants have indicated that registered funds with more complex strategies 

and certain types of closed-end funds, such as those that only strike net asset values once per 

month, may not receive certain data until shortly before the 30-day deadline, increasing the 

potential for errors and resubmissions and potentially causing some registered fund industry 

 
110  See 2024 Adopting Release, supra note 1, at nn. 204-206 and accompanying text for a more detailed 

discussion of these effects. 
111  See id. at nn. 221-223 and accompanying text. See also ICI Letter at note 23. 



76 
 

participants to hire additional personnel to manage the condensed timeframe.112 The 45-day 

filing deadline would mitigate these costs for such funds.  

The proposed 45-day filing deadline would delay the Commission’s receipt of monthly 

Form N-PORT filings by 15 days. As discussed in the 2024 Adopting Release, the timely receipt 

of Form N-PORT information allows the Commission to conduct targeted and timely monitoring 

efforts, to accurately analyze risks and trends, and to assess the breadth and magnitude of 

potential impacts of market events and stress affecting particular issuers, asset classes, 

counterparties, or market participants.113 Therefore, the benefits associated with timely 

Commission oversight, such as reduced investor harm or market disruptions, may decrease as a 

result of the 15-day delay. However, the Commission would still have more timely access to 

registered fund information than it does under the quarterly filing requirements that are currently 

in effect. 

2. Publication Frequency 

We are proposing to require public disclosure of registered funds’ portfolio holdings for 

the third month of each fiscal quarter with a 60-day delay. While the proposal would reduce the 

amount of information available to investors about registered fund holdings relative to the 

monthly portfolio disclosure required by the 2024 amendments, it would also reduce the risk that 

a fund’s proprietary investment strategy or trading intentions are inferred by external parties. 

The primary benefits of the proposed decrease in publication frequency would be to 

reduce certain costs that an increased publication frequency could impose on registered funds.114 

The monthly publication frequency required by the 2024 amendments would provide market 

 
112  See supra section II.A and paragraph accompanying n.13. 
113  See 2024 Adopting Release, supra note 1, at n. 198 and accompanying text. 
114  See id. at n. 237 and accompanying text. 



77 
 

participants with four times more data annually regarding a registered fund’s holdings, 

increasing the risk that a fund’s proprietary investment strategy could be copied by funds that do 

not incur the information production costs of the target fund, and may reduce the returns of the 

target fund.115 In addition, because the 2024 amendments reduce the maximum potential time 

that a registered fund can use to, for example, build a position in a new fund holding from 

approximately five months to approximately three months, funds that tend to establish or dispose 

of positions over periods of time longer than three months risk having their trading intentions 

inferred sooner than is the case under the rules currently in effect.116 While a registered fund’s 

trading intentions or the information on which it is basing its proprietary investment strategy may 

be reflected in the market through other channels, such as the trades a fund initiates in the 

interim, the revelation of a fund’s holdings via Form N-PORT before it has fully established or 

disposed of a position could increase the associated trading costs and reduce returns for its 

investors.117 The proposed changes to the publication frequency would therefore reduce any 

trading costs associated with the publication of registered fund holdings on Form N-PORT. 

While the 2024 Adopting Release acknowledged that increasing the publication 

frequency of Form N-PORT could affect a registered fund’s business practices by, for example, 

altering the fund’s trading strategy around disclosure dates,118 market participants have since 

reiterated the potential costs that the more frequent publication of holdings could impose on 

 
115  See supra notes 102-103 and accompanying text. 
116  Under the requirements prior to the 2024 amendments, if a registered fund, for example, begins to establish 

a new position immediately after quarter-end, the position will not be publicly disclosed for 3 months and 
60 days (i.e., about 5 months in total). Under the 2024 amendments, if a registered fund begins to establish 
a new position immediately after quarter-end, the position will not be publicly disclosed for 1 month and 60 
days (i.e., about 3 months in total). 

117  See 2024 Adopting Release, supra note 1, at n. 240 and accompanying text. 
118  See id. at n. 248. 



78 
 

actively managed funds and their shareholders, and the subsequent need funds may have to alter 

their investment strategies to mitigate these costs.119 These costs could also lead a registered 

fund to decrease its research expenditures or, in the extreme, conclude that a given investment 

strategy is not viable and stop offering it, which could decrease price efficiency as well as 

investor choice.120  

The costs of the proposed amendments include the loss of several benefits to investors 

and other users of Form N-PORT associated with a monthly publication frequency 60 days after 

the end of each reporting period, such as an enhanced ability of investors to review and monitor 

information on registered funds’ portfolios (directly or through analyses performed by third-

party data aggregators). These forgone benefits would include a reduced need to rely on 

registered funds’ voluntary holdings disclosures, which are not consistently provided by all 

registered funds and, even where they are, may have formats that are inconsistent across time or 

across funds, or may be difficult to access.121 In addition, voluntary disclosures do not 

necessarily contain other potentially useful information that is contained on Form N-PORT, such 

as a registered fund’s net assets, liabilities, flows, interest rate risk, credit risk, or counterparty 

risk. Moreover, even where market participants use quarterly Form N-PORT data, registered 

funds report these data in accordance with their own fiscal years, which may differ and preclude 

the comparison of different funds at a given point in time.122 Finally, to the extent more frequent 

Form N-PORT disclosures would have ameliorated agency problems that may exist between a 

registered fund’s manager and the fund’s investors, any benefits investors would have accrued 

 
119  See ICI Letter. 
120  See supra section III.B.3.  
121  See 2024 Adopting Release, supra note 1, at n. 231. 
122  See id. at 73784 (Table 2). 



79 
 

due to a reduction in these agency problems under the 2024 Amendments would no longer 

apply.123 

3. Other Proposed Amendments to Form N-PORT 

We are also proposing amendments to Form N-PORT to refine the information registered 

funds provide. Specifically, we are proposing to modify certain information collected on 

portfolio level risk metrics and returns to narrow their scope, and proposing to eliminate certain 

information collected on non-derivatives instruments’ payoff profiles, convertible bonds, names 

rule compliance, and the reason a single holding has multiple liquidity classifications. We are 

also proposing to modify how funds with ETF share classes report net assets and shareholder 

flows to require separate information for ETF share classes. Finally, we are proposing to require 

registered funds to provide ticker symbols by registrant, and for each class of a registrant or 

series, as applicable, as well as certain other class-level information, if any, to help staff and data 

users use data more efficiently. Throughout this discussion, when we refer to the potential use of 

Form N-PORT by investors, we note that investors may use the information directly or by 

relying on third parties that aggregate the information available on Form N-PORT and provide it 

to investors and other market participants. We also generally refer to the costs (or cost savings) 

associated with the proposed changes as being incurred by, or accrued to, a fund, but note that all 

of the costs or cost savings discussed below may be passed onto fund investors. 

The proposed modifications to the information collected on portfolio level risk metrics 

include an increase in the threshold percentage of registered fund assets held in debt or debt 

derivatives that triggers risk metric reporting requirements, the removal of risk metrics 

 
123  See id. at nn. 234-236 and accompanying text for a discussion of potential agency problems that may be 

mitigated by more frequent portfolio disclosure.   



80 
 

associated with small changes in interest rates (DV01), the aggregation of risk metrics associated 

with larger changes in interest rates (DV100) (rather than separate DV100 reporting for each 

currency that a registered fund has holdings of that amount to 1% or more of the fund’s net asset 

value), the aggregation of credit risk metrics for investment-grade and non-investment grade into 

a single credit risk metric, and a clarification that risk metrics are reported in US dollars. These 

changes would reduce the costs associated with reporting risk metrics on Form N-PORT by 

reducing the number of registered funds that are required to report the metrics, removing certain 

metrics (DV01), and streamlining the reporting of the remaining metrics. To the extent investors 

currently rely on the risk metrics that will be removed or streamlined, the amendments would 

reduce the amount of information on which investors can base their investment decisions. We do 

not expect these changes to significantly affect the utility of the reported information about 

portfolio risk metrics to the Commission.124  

The proposed modifications to the information collected on registered fund returns would 

require that funds with multiple share classes only report return information for a single 

representative class, rather than reporting returns for each share class. This change should reduce 

the costs associated with filing such return information while still providing investors and the 

Commission with fundamental information on a registered fund’s monthly returns. In addition, 

the proposed changes would exclude sales loads and redemption fees from monthly return 

calculations, which would remove the ambiguous effect that these fees have on such monthly 

returns for investors who hold a fund for different lengths of time. Investors would still have 

access to return information reflecting sales loads and redemption fees over several hypothetical 

holding periods for relevant registered funds on Forms N-1A and N-3, and these fees are 

 
124  See supra note 43 and subsequent text.81 
 

explicitly disclosed in a fund’s prospectus. In addition, some registered funds already exclude 

sales loads and redemption fees from their monthly fund returns on Form N-PORT, so we do not 

expect the removal of these fees from monthly return calculations to impose significant costs on 

investors.125   

While registered funds would continue to report the net realized gain and net change in 

unrealized appreciation attributable to derivatives for multiple asset categories, funds would no 

longer be required to separately report this information for each type of derivative within each 

asset category, reducing reporting costs for funds. To the extent investors currently rely on the 

more granular reporting by derivative type within each asset category, the amendments would 

reduce the amount of information on which investors can base their investment decisions. 

In addition, the proposed changes would remove several items from Form N-PORT 

altogether, which would reduce reporting costs for registered funds. For positions that are not 

derivatives, registered funds would no longer have to classify the payoff profile (long, short, or 

N/A) of the position. While the explicit item capturing the payoff profile of such positions would 

no longer be available to investors, investors would still be able to determine a position’s payoff 

profile from the sign of the corresponding holding reported on Form N-PORT. We are also 

proposing to remove both the conversion ratio and the delta for convertible debt securities from 

Form N-PORT. To the extent investors rely on the conversion ratio information, they will have 

less information on which to base their investment decisions. In addition, the proposed changes 

would no longer require an open-end fund that is attributing multiple liquidity classifications to a 

holding to indicate the reason the holding requires multiple classifications. Because liquidity 

classifications are not publicly reported, this change would not impose costs on investors.  

 
125  See supra note 89. 



82 
 

The proposed changes discussed above either reduce the content of, or eliminate, certain 

items from Form N-PORT, which will reduce the amount of information available to the 

Commission for oversight purposes. However, based on our experience, not having this data 

would not adversely affect our oversight capabilities, so we do not expect them to reduce 

investor protections. 

In addition to the Form N-PORT items that we are proposing to remove or streamline 

based on Commission experience using the information provided by registered funds on Form N-

PORT, we are also proposing to remove three items from Form N-PORT that were adopted as 

part of amendments to the names rule, which funds have not yet begun to report.126 These 

disclosures apply to registered funds required to adopt an 80% investment policy and include: (1) 

definitions of terms used in the fund’s name; (2) the value of the fund’s 80% basket, as a 

percentage of the value of the fund’s assets; and (3) whether each investment in the fund’s 

portfolio is in the fund’s 80% basket.127 Removing these items would eliminate the costs 

registered funds would incur associated with modifications to internal compliance systems, the 

potential use of third-party service providers in filing these items, and the need to add new data 

tags for these items for purposes of filing the names rule relevant items on Form N-PORT.128 

While the Commission would still be able to perform oversight of a fund’s compliance with the 

names rule due to the rule’s recordkeeping and other disclosure requirements, the removal from 

Form N-PORT of individual holding classifications under the names rule as well as the aggregate 

value of a fund’s 80% basket could reduce the efficacy of the Commission’s oversight, such as 

its ability to conduct targeted exams. In addition, to the extent that investors would have relied 

 
126  See Names Rule Adopting Release, supra note 10. 
127  See Items B.11 and C.2.e of current Form N-PORT. 
128  See Names Rule Adopting Release, supra note 10, at paragraphs accompanying nn.571-574. 



83 
 

on the information on Form N-PORT regarding names rule compliance, either directly or 

through third parties, to better determine whether or not a registered fund’s investment strategy is 

consistent with their goals and preferences, the removal of these items would reduce their ability 

to do so. For a fund with an 80% investment policy, investors would still have access to the 

definition of terms used in the fund’s name and any selection criteria associated with these terms 

in the fund’s prospectus, as well as information about the fund’s portfolio holdings, which may 

mitigate this effect. 

The proposed changes to Form N-PORT also include a new item tailored to registered 

funds with ETF share classes. Funds with ETF share classes would be required to provide 

identifying information for the share class, information on the net assets associated with the 

share class, and information on flows into and out of the share class. Investors and market 

participants would benefit from these changes by gaining a more detailed understanding of the 

differences in size and flows of a fund’s ETF and non-ETF share classes, particularly if the 

number of funds offering ETF share classes increases. Finally, these changes would allow the 

Commission to monitor and respond to any issues that arise if the number of registered funds and 

the amount of assets managed using ETF share classes increase in the future. Funds that have an 

ETF share class would incur costs associated with identifying, validating, and filing these new 

items on Form N-PORT. 

Finally, we are proposing to require registered funds to provide ticker symbols by 

registrant, and for each class of a registrant or series, as applicable, as well as certain other class-

level information, if any, to help staff and data users use data more efficiently.129 As discussed 

above, using the identifying information that registered funds currently report to match a fund, 

 
129  See supra note 75. 



84 
 

series, and/or class across multiple data sources (e.g., Form N-PORT reports, other reports such 

as Form N-CEN, and third-party vendor information) can be difficult because of slight 

differences in the reported name of the fund, series, and/or class as well as the lack of LEIs or 

EDGAR series identifiers in some data sources.130 The additional identifying information 

required for registrants and each class of a registrant or series would improve the Commission’s 

ability to monitor and analyze registered fund activity across data sources, enhancing investor 

protections. The additional identifying information would also improve the ability of investors to 

compare funds and individual share classes and series across different data sources, allowing 

them to make more informed investment decisions. Registered funds would incur costs 

associated with validating and filing these new items on Form N-PORT. 

4. Monetized Benefits and Costs 

This section estimates the monetized benefits and costs of the proposed amendments by 

disaggregating the net reduction in PRA burden discussed in section IV.131  These estimates are 

then used in the following section to calculate present and annualized values of the benefits and 

costs of the proposed amendments under different discount rate assumptions. These estimates are 

expected to be lower bounds on the benefits and costs registered funds and their investors would 

experience because we are not able to quantify all of the economic effects of the proposed 

changes.132 

 
130  See supra note 77 and preceding discussion. 
131  The monetization in this section reflects the reduction in PRA burden discussed in section IV. As noted 

there, this reduction includes consideration of the additional costs that would be imposed by adding 
information about ETF share classes and by adding additional identifying information. See infra note 162. 
Also note that while we estimate that 9,628 funds would be affected by names-rule related changes to Form 
N-PORT in section III.B.2, the cost saving estimates reflect the number of funds (9,926) used to calculate 
the associated PRA burden (see section IV, Table 8, note 7). 

132  See supra note 87 and preceding discussion. 



85 
 

We estimate that registered funds would experience net one-time cost savings of 

$94,013,000 associated with the change in filing timeframe from 30 days to 45 days and the 

various amendments to Form N-PORT.133 These one-time cost savings are net of the aggregate 

one-time costs of $2,923,142 that we estimate are associated with the information about ETF 

share classes and the additional identifying information that would be required by the proposed 

amendments.134 Therefore, we estimate that registered funds would benefit from gross one-time 

costs savings of $96,936,142 as a result of the proposed amendments.135 

Similarly, we estimate that registered funds would experience net ongoing cost savings of 

$95,955,431 associated with the change in filing timeframe from 30 days to 45 days and the 

various amendments to Form N-PORT.136 These ongoing cost savings are net of the aggregate 

 
133  See section IV, Table 8. Registered funds that license a software solution to file Form N-PORT are 

expected to experience aggregate one-time cost savings of $6,105,618 (4,434 funds * 3 hours * $459 per 
hour), while those that outsource filing Form N-PORT to a third-party are expected to experience aggregate 
one-time cost savings of $11,338,218 (8,234 funds * 3 hours * $459 per hour). In addition, registered funds 
affected by the names rule are expected to experience one-time aggregate cost savings of $76,569,164 
(9,926 funds * 19 hours * $406 per hour). Total aggregate one-time cost savings based on the information 
in Table 8 are therefore expected to be $94,013,000 ($6,105,618 + $11,338,218 + $76,569,164). Note that, 
while we estimate that 9,628 funds will be affected by names-rule related changes to Form N-PORT in 
section III.B.2, these cost estimates reflect the number of funds used to calculate the associated PRA 
burden (see section IV, Table 8, note 7). 

134  As noted in section III.B.2, we estimate that 69 registered funds would be required to file information about 
ETF share classes. We estimate that these registered funds would incur an initial burden of 0.5 hours 
associated with filing ETF information at a blended wage rate of $459 per hour, implying initial aggregate 
costs of $15,836 (69 funds * 0.5 hours * $459 per hour). All 12,668 registered funds currently required to 
file reports on Form N-PORT would be required to file the additional identifying information, and we 
estimate that these funds would incur an initial burden of 0.5 hours at a blended wage rate of $459 per hour, 
implying initial aggregate costs of $2,907,306 (12,668 funds * 0.5 hours * $459 per hour). Total aggregate 
one-time costs associated with the additional information we are requiring on Form N-PORT are therefore 
expected to be $2,923,142 ($15,836 + $2,907,306). 

135  $96,936,142 = $94,013,000 + $2,923,142. 
136  See section IV, Table 8. Note that internal annual burden hours reported in the table include initial burden 

estimates annualized over a 3-year period. To isolate ongoing economic burden hours, we thus reduce the 
internal annual burden hours by one third of the initial internal burden hours, both as reported in Table 8. 
Registered funds that license a software solution to file Form N-PORT are expected to save $6,105,618 
(4,434 funds * 3 hours * $459 per hours) in aggregate annually due to a reduction in internal hours spent 
filing Form N-PORT and to save $4,434,000 (4,434 funds * $1,000 per fund) from reduced costs associated 
with external services. Similarly, registered funds that outsource filing Form N-PORT to a third-party are 
expected to save $7,558,812 (8,234 funds * 2 hours * $459 per hour) in aggregate annually due to a 
 



86 
 

ongoing costs of $1,461,571 that we estimate are associated with the information about ETF 

share classes and the additional identifying information that would be required by the proposed 

amendments.137 Therefore, we estimate that registered funds would benefit from gross ongoing 

costs savings of $97,417,002 as a result of the proposed amendments.138 

5. Present Values and Annualized Values of Monetized Benefits and Costs 

In this section, we report the total monetized benefits and costs of the proposed 

amendments, as calculated in the previous section, in two additional ways. These presentations 

are intended to address the fact that the various benefits and costs of the proposed amendments 

would not accrue at the same point in time; rather, benefits and costs that accrue sooner are 

generally more valuable than those that occur later in time. Specifically, we report below: (1) the 

present values of expected benefits and costs that are monetized in our economic analysis over a 

10-year time horizon, starting in 2026, as well as (2) the annualized values over the same time 

horizon that are derived from the present values. This 10-year time horizon represents the period 

over which the principal benefits and costs that are monetized in the economic analysis are 

 
reduction in internal hours spent filing Form N-PORT and to save $16,468,000 (8,234 funds * $2,000) 
from reduced costs associated with external services. In addition, registered funds affected by the names 
rule are expected to experience annual cost savings of $38,956,241 (9,926 funds * 9.67 hours * $406 per 
hour) due to a reduction in internal hours spent filing names-related information on Form N-PORT and to 
save $22,432,760 (9,926 funds * $2,260) from reduced costs associated with external services. Total 
aggregate cost savings are therefore expected to be $95,955,431 ($6,105,618 + $4,434,000 + $7,558,812 + 
$16,468,000 + $38,956,241 + $22,432,760). 

137  As noted in section III.B.2, we estimate that 69 funds would be required to file information about ETF 
share classes. We estimate that these registered funds would spend an additional 0.25 hours annually 
associated with filing ETF information at a blended wage rate of $459 per hour, implying ongoing 
aggregate annual costs of $7,918 (69 funds * 0.25 hours * $459 per hour). All 12,668 registered funds 
currently required to file reports on Form N-PORT would be required to file the additional identifying 
information, and we estimate that these funds would spend an additional 0.25 hours annually at a blended 
wage rate of $459 per hour, implying ongoing aggregate annual costs of $1,453,653 (12,668 funds * 0.25 
hours * $459 per hour). Total aggregate annual costs associated with these changes are therefore expected 
to be $1,461,571 ($7,918 + $1,453,653).  

138  $97,417,002 = $95,955,431 + $1,461,571. 



87 
 

expected to accrue.139 The present values and annualized values account for the timing of 

benefits and costs through discounting, which is a procedure that accounts for the time value of 

money.140 The present values and annualized values are computed for total monetized benefits 

and costs, combining one-time and recurring monetized benefits and costs, across all affected 

entities over the time horizon. 

Table 6 reports the present values of monetized benefits and costs using annual real 

discount rates of 3 percent and 7 percent over a 10-year time horizon, starting in 2026.141  

Table 6. Present Value of Monetized Benefits and Costs  

Over a 10-year Time Horizon (in 2025 $)1  

Estimated Effects2 3% real discount rate 7% real discount rate 
Benefits $844,307,797 $710,518,371 

Costs $14,136,138 $12,128,864 
 

1   This Table includes only benefits and costs that are monetized. As discussed in this economic analysis, there are 
other benefits and costs that we are not able to monetize. 

2   For each discount rate, the present value of monetized benefits or costs is calculated assuming that: (i) all one-time 
monetized implementation benefits and costs are immediately incurred (i.e., these costs are not discounted); (ii) 
recurring annual monetized benefits and costs start to be incurred as of the year in which affected entities first 
comply. In (iii), we assume that monetized benefits and costs accrue mid-year, and we use a mid-year discount rate. 
We are proposing a 12-month transition period for larger entities and an 18-month period for smaller entities. 
Correspondingly, both groups of entities would start complying with the proposed rule in the same calendar year 
(2027 for the purposes of this calculation), and we therefore discount the cash flows for both entities at mid-year of 
the same calendar year in our present value calculations. 

 
139  See OMB, CIRCULAR A-4, at 31-34 (Sept. 17, 2003) at 31 (stating that “[t]he ending point should be far 

enough in the future to encompass all the significant benefits and costs likely to result from the rule”). For 
the purposes of this analysis, we assume the effective date of the rule, as well as the start year for the 
analysis’s 10-year time horizon, is the present year. The analysis uses calendar years and also accounts for 
the compliance periods included in the release (see note 2 in Table 6). 

140  See id. at 32 (“The Rationale for Discounting”) and 45 (“Treatment of Benefits and Costs over Time”). See 
also OIRA, REGULATORY IMPACT ANALYSIS: A PRIMER, at 11 (Aug. 15, 2011), available at 
https://www.reginfo.gov/public/jsp/Utilities/circular-a-4_regulatory-impact-analysis-a-primer.pdf (“To 
provide an accurate assessment of benefits and costs that occur at different points in time or over different 
time horizons, an agency should use discounting. Agencies should provide benefit and cost estimates using 
both 3 percent and 7 percent annual discount rates expressed as a present value as well as annualized.”). 
See also, e.g., HARVEY S. ROSEN & TED GAYER, PUBLIC FINANCE 151 (8th ed. 2008) (defining present 
value as “the value today of a given amount of money to be paid or received in the future”). 

141  This approach is consistent with OMB Circular A-4. See id at 31-34 (stating that, “[f]or regulatory analysis, 
[agencies] should provide estimates of net benefits using both 3 percent and 7 percent” discount rates and 
discussing why those rates are reasonable default rates).  

https://www.reginfo.gov/public/jsp/Utilities/circular-a-4_regulatory-impact-analysis-a-primer.pdf


88 
 

 

Table 7 reports annualized monetized benefits and costs using real discount rates of 3 

percent and 7 percent over a 10-year horizon, starting in 2026.142 The lump sum present values of 

monetized benefits and costs reported in Table 6 are converted in Table 7 into a constant stream of 

annualized benefits and costs over a 10-year time horizon.143 Annualized benefits and costs may 

differ from any recurring annual benefits and costs discussed earlier in this economic analysis 

because they incorporate the timing of benefits and costs, through discounting, and combine one-

time and recurring benefits and costs.144  

Table 7. Annualized Monetized Benefits and Costs over a 10-year Time Horizon (in 2025 $) 1  

Estimated Effects2 3% real discount rate 7% real discount rate 
Benefits $97,526,543 $97,796,834 

Costs $1,632,875 $1,669,435 
 

1   This Table includes only benefits and costs that are monetized. As discussed in this economic analysis, there 
are other benefits and costs that we are not able to monetize. 

2   For each discount rate, the annualized value of monetized benefits (costs, respectively) is calculated by 
dividing the corresponding present value of monetized benefits (costs, respectively) in Table 6 by the sum of 
discount factors over the 10-year time horizon. The discount factor in year t of the 10-year time horizon (t = 1, 
…, 10) is equal to 1 / (1 + discount rate)^(t-0.5)), where the discount rate is either 3% or 7%. The sum of 
discount factors over the 10-year time horizon is then the sum of the discount factors across years t = 1 
through 10. 

 

In sum, Tables 6 and 7 report in two alternative ways expected total benefits and costs, 

across all affected entities, which are monetized in our economic analysis, using real discount rates 

of 3 percent and 7 percent over a 10-year time horizon. 
 

 
142  This approach is consistent with the recommended treatment of benefits and costs over time in Circular A-

4. See id. at 45 (“You should present annualized benefits and costs using real discount rates of 3 and 7 
percent”). 

143  For each discount rate, the annualized monetized benefits (costs, respectively) in Table 7 represent the 
constant annual stream of benefits (costs, respectively) whose present value over the 10-year horizon 
equates the corresponding present value in Table 6. See note 2, Table 7 for additional calculation details. 

144  The annualized benefits and costs present these values over the 10-year time horizon, starting in the present 
year, even if recurring annual benefits and costs would actually start to be incurred at a later date due to 
compliance periods.  



89 
 

D. Effects on Efficiency, Competition, and Capital Formation 

1. Efficiency 

By reducing the frequency at which a registered fund’s portfolio holdings are disclosed 

on Form N-PORT relative to the 2024 amendments, the proposed amendments reduce the risk 

that external parties infer the fund’s proprietary investment strategy or trading intentions and use 

that information in ways that increase costs for the fund and its shareholders.145 Under the 2024 

amendments, concerns about such costs could cause registered funds to alter their business 

practices in ways that reduce information production,146 potentially reducing the price efficiency 

of the securities funds hold.147 Specifically, a registered fund might decide to reduce its 

investment in researching securities if the fund expects the returns to performing such research 

will be reduced by increased disclosure of the fund’s holdings on Form N-PORT, or to forgo an 

investment strategy altogether. To the extent that the potential costs associated with more 

frequent portfolio disclosure under the baseline would cause registered funds to reduce their 

information production, the proposed amendments would eliminate this disincentive, increasing 

price efficiency. 

The proposed changes would reduce the frequency and consistency of registered fund 

holding disclosures, which could reduce the ability of investors to monitor funds’ portfolios and 

make investment decisions that are more aligned with their objectives and risk tolerance, 

decreasing allocative efficiency.148 In addition, price efficiency might decrease if investors 

would have used the more frequent disclosure of registered fund holding valuations contained on 

 
145  See supra notes 115 to 117. 
146  See supra notes 118 to 119. 
147  See 2024 Adopting Release, supra note 1, at section IV.D.1. 
148  See id. at n. 260. 



90 
 

Form N-PORT (which may be useful for holdings that are not traded on an exchange) and the 

knowledge that certain registered funds are holding a particular security to inform their 

investment decisions under the baseline.149 Finally, price efficiency in the secondary market for 

shares of closed-end funds could be reduced to the extent that investors would have used the 

more frequent disclosure of closed-end fund holdings to better value these shares prior to 

transacting in the secondary market.150 

The other proposed amendments to Form N-PORT are not expected to have significant 

effects on efficiency, competition, or capital formation. If anything, they may have a marginal 

effect on allocative efficiency to the extent they change the information available to investors in 

selecting investments that match their objectives or risk preferences. For example, additional 

information on the net assets and shareholder flows for ETF share classes as well as more robust 

identifying information for fund registrants, share classes, and series may allow investors to 

make marginally more efficient investment decisions. In contrast, the elimination of certain 

information as well as the narrowing of scope for other information may marginally reduce the 

efficiency of investors’ investment decisions. In the latter case, any marginal negative effects on 

investment efficiency may be mitigated by the continuing availability of relevant information 

elsewhere on Form N-PORT or in other filings. For example, investors or third parties may be 

able to compute certain items that are being streamlined or removed from Form N-PORT directly 

from registered funds’ published quarterly holdings. In such cases, the effect of the proposed 

changes would be limited to a decrease in such information during the two months between 

quarters during which holdings are reported. 

 
149 See id. at nn. 262-263 and accompanying text. 
150  See id. at discussion in last paragraph of section IV.D.1. 



91 
 

2. Competition 

By increasing the time registered funds have to file Form N-PORT from 30 days to 45 

days, the proposed amendments would mitigate compliance costs that, as a percentage of assets 

under management, likely would have been higher for smaller funds and fund complexes.151 In 

doing so, the proposed amendments could increase, relative to the 2024 amendments, these 

smaller funds’ ability to compete with larger funds and fund complexes. Similarly, to the extent 

that registered funds would have passed on compliance costs associated with the 2024 

amendments to their investors, the proposed changes would mitigate any reduction in the 

competitiveness of registered funds relative to other investment vehicles such as collective 

investment trusts or separately managed accounts.152  

To the extent that the increased frequency and consistency of the information investors 

would have had about registered fund holdings under the 2024 amendments would have allowed 

them to better understand and compare the drivers of fund performance, the proposed changes 

could reduce competition between registered funds.153  

3. Capital Formation 

To the extent that the potential costs associated with more frequent holdings disclosure 

under the 2024 amendments would disincentivize registered funds from investing in costly 

information production activities, such as performing fundamental research on securities, or 

cause them to forgo certain investment strategies and their associated information production 

activities altogether, the proposed changes would reduce this disincentive, increasing the price 

 
151 See id. at section IV.D.2. 
152  See id. at n. 265. 
153 See id. at text following n. 266. 



92 
 

efficiency of registered fund holdings.154 In turn, more informative prices could lead the issuers 

of the securities held by registered funds to make more efficient capital allocation decisions.155 

In contrast, to the extent that more frequent and consistent information on registered fund 

holdings under the 2024 amendments would have increased price efficiency by improving 

investors’ ability to value securities, ultimately leading to better decisions by issuers on how 

capital is allocated, the proposed revision of Form N-PORT’s publication frequency from 

monthly to quarterly could eliminate any such positive effect on capital formation.156 

E. Reasonable Alternatives 

1. Filing Timeframe 

The Commission is proposing to extend the time registered funds have to file monthly 

Form N-PORT reports with the Commission from 30 days to 45 days. As an alternative, as with 

the 2024 amendments, we considered an even longer filing deadline (e.g., 60 days after each 

month end). A longer filing deadline would provide registered funds with even more time to 

gather, verify, and file information required on Form N-PORT, which could reduce the direct 

costs associated with these activities. In addition, a longer filing deadline could reduce the 

indirect costs associated with filing errors and any subsequent amendments to a registered fund’s 

Form N-PORT reports. At the same time, a longer time to file could reduce the utility of 

information reported on Form N-PORT in exercising the Commission’s oversight 

responsibilities, especially during periods of market stress in which the analysis of potential 

issues and development of any regulatory responses are particularly time sensitive endeavors. 

 
154  See supra notes 118 to 119. 
155  See supra note 108. 
156  See 2024 Adopting Release, supra note 1, at section IV.D.3. 



93 
 

2. Publication of Registered Fund Holdings 

We are proposing to require public disclosure of registered funds’ portfolio holdings for 

the third month of each fiscal quarter with a 60-day delay. As an alternative, we considered 

synchronizing those disclosures across registered funds to occur in the same month of each 

quarter rather than according to each fund’s specific fiscal year schedule, while maintaining the 

60-day delay. While a synchronized quarterly publication requirement would allow investors to 

compare registered fund holdings at the same point in time, funds whose fiscal year-ends are not 

aligned with the synchronized schedule would end up disclosing their holdings more than four 

times per year due to the separate requirement that funds disclose a full schedule of investments 

with their financial statements. This would be more costly for such funds and may expose them 

to a greater risk that external parties may use the more frequent disclosures of the registered 

funds’ portfolio holdings to infer the fund’s proprietary investment strategy or trading intentions 

and use that information in ways that increase costs for the funds and their shareholders, making 

them less competitive than registered funds with fiscal year-ends that are aligned with the 

synchronized schedule. Under this alternative, registered funds could mitigate any risks 

associated with these additional disclosures by adjusting their fiscal year to align with the 

synchronized publication schedule, though they would incur additional costs in doing so. 

As another alternative to the proposed quarterly publication of registered funds’ portfolio 

holdings, we considered retaining the monthly publication frequency from the 2024 

amendments, but with a longer period before publication (e.g., 90 days after month end, or 60 

days after the end of the quarter to which the monthly reports relate). This alternative would 

result in additional time for registered funds to build or dispose of positions before Form N-

PORT reports would provide public information about changes in their portfolio holdings. As a 



94 
 

result, the alternative would reduce the risk that external parties could infer information about a 

registered fund’s trading intentions before the fund has fully established its position in a security 

and may reduce the cost of establishing the position relative to the 2024 amendments. However, 

this alternative would be less effective than the proposed approach in reducing the risk that a 

registered fund’s overall trading strategy is inferred by external parties, as funds’ portfolio 

holdings would continue to be published for every month. 

IV. Paperwork Reduction Act 

A. Introduction 

Certain provisions of the proposed amendments contain “collection of information” 

requirements within the meaning of the Paperwork Reduction Act of 1995 (the “PRA”).157 We 

will submit the proposed collections of information to the Office of Management and Budget 

(“OMB”) for review in accordance with the PRA.158 The proposed amendments would change 

the current collection of information burdens of Form N-PORT under the Investment Company 

Act. 

The title for the existing collection of information is “Rule 30b1-9 and Form N-PORT” 

(OMB control number 3235-0730). An agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a currently valid OMB 

control number. Each requirement to disclose information constitutes a collection of information 

requirement under the PRA. These collections of information would provide information to the 

Commission and investors. The Commission staff would also use the collection of information in 

 
157  44 U.S.C. 3501–3521. 
158  44 U.S.C. 3507(d); 5 CFR 1320.11. 



95 
 

its examination and oversight programs in identifying patterns and trends across registrants. We 

discuss below the collection of information burdens associated with the proposed amendments. 

B. Form N-PORT 

Form N-PORT requires registered management investment companies (except for money 

market funds and small business investment companies) and ETFs that are organized as unit 

investment trusts to report portfolio holdings information in a structured, XML data language. 

The form is filed electronically using the Commission’s electronic filing system, EDGAR. We 

propose the following amendments to Form N-PORT: 

• Filing timeframe. The proposed amendments to rule 30b1-9 and Form N-PORT 

would require registered funds to file Form N-PORT reports within 45 days after the 

end of the month to which they relate rather than filing monthly reports 30 days after 

the end of each calendar month under the 2024 amendments.  

• Publication frequency. The proposed amendments to Form N-PORT would require 

publication of Form N-PORT reports for the third month of each fiscal quarter with a 

60-day delay, instead of publication of monthly reports with a 60-day delay under the 

2024 amendments.  

• Other proposed amendments. The proposed amendments to Form N-PORT would 

modify certain information collected on portfolio level risk metrics and returns to 

narrow their scope; eliminate certain information collected on registered funds’ 

compliance with names rule-related regulatory requirements, non-derivatives 

instruments’ payoff profiles, convertible bonds, and the reason a single holding has 

multiple liquidity classifications; require funds with ETF share classes to report net 



96 
 

assets and shareholder flows separately for ETF share classes; and require registered 

funds to report additional identifying information, such as tickers. 

The respondents to these collections of information would be management investment 

companies (other than money market funds and small business investment companies) and ETFs 

that are organized as unit investment trusts. We estimate that there are 12,668 such funds 

required to file on Form N-PORT.159 The proposed collections of information are mandatory for 

the identified types of funds. Certain information reported on the form is currently kept 

confidential, and we propose that this would continue to be the case.160  

In the most recent PRA submission for Form N-PORT, the Commission estimated the 

annual aggregate compliance burden to comply with the current collection of information 

requirements in Form N-PORT is 2,000,834 burden hours and an external cost burden estimate 

of $177,742,893.161 While the amendments in the 2024 Adopting Release have not gone into 

effect, the approved PRA estimates reflect those amendments. As a result, the current burden 

estimates reflect the burden hours and external costs associated with a requirement for registered 

funds to file monthly reports with the Commission within 30 days of month end. In connection 

with the 2024 amendments, the Commission did not estimate additional burdens associated with 

changing the publication frequency of Form N-PORT reports.  

We estimate that registered funds prepare and file their reports on Form N-PORT either 

by: (1) licensing a software solution and preparing and filing the reports in house, or (2) retaining 

a service provider to provide data aggregation, validation, and/or filing services as part of the 

 
159  This estimate of the number of registered funds required to file on Form N-PORT is as of Dec. 31, 2024, 

and based on data from filings with the Commission. 
160  See General Instruction F of Form N-PORT; General Instruction F of amended Form N-PORT.  
161  The most recent Form N-PORT PRA submission was approved in 2024 (OMB Control No. 3235-0730). 



97 
 

preparation and filing of reports on behalf of the fund. We estimate that 35% of funds subject to 

the Form N-PORT filing requirements license a software solution and file reports on Form N-

PORT in house, and the remaining 65% retain a service provider to file reports on behalf of the 

fund. 

We are adjusting downward the collection of information burden in connection with the 

proposed requirement to file Form N-PORT reports within 45 days of month end, rather than 

within 30 days of month end. This reduction reflects that burdens of collecting and filing Form 

N-PORT information should be lower because registered funds will have more time to conduct 

these activities and avoid corrective re-submissions of filings. We are not proposing any 

adjustment to the burden estimates in connection with the proposed changes to the publication 

frequency of Form N-PORT reports, as the Commission similarly did not adjust burden estimates 

in 2024, and there is no separate information collection involved with the Commission 

publishing reports that have been filed with us. We are also adjusting downward the collection of 

information burden in connection with the modifications to and elimination of certain items in 

Form N-PORT. This reduction reflects that burdens of collecting and filing Form N-PORT 

information should be lower because registered funds would be required to collect and report less 

overall information.162 

Table 8 below summarizes our initial and ongoing annual burden estimates associated 

with the proposed amendments to Form N-PORT. The following estimates of average burden 

hours and costs are made solely for purposes of the Paperwork Reduction Act. 

  

 
162  This adjustment downward includes consideration of the additional collection of information burden that 

would be imposed by adding information about ETF share classes and by adding additional identifying 
information. 



98 
 

Table 8. Form N-PORT PRA Estimates 

 Initial 
internal 
burden 
hours 

Internal annual 
burden hours1  

Wage 
rate Internal time costs 

Annual external cost 
burden 

PROPOSED AMENDMENTS TO FORM N-PORT 

 

Proposed Amendments to Filing Timeframe and Other Proposed Amendments (Excluding Removal of Names Rule-Related Reporting)  

Funds that license a 
software solution to 
prepare Form N-PORT 

-3 hours -4 hours3 x $4592 -$1,836 -$1,0004 

Number of funds5  × 4,434 funds   × 4,434 funds x 4,434 funds 

Funds that retain the 
services of a third-party 
vendor to prepare Form 
N-PORT 

-3 hours -3 hours6 x $4592 -$1,377 -$2,0007 

Number of funds5  × 8,234 funds   × 8,234 funds x 8,234 funds 

Total new annual 
burden of amendments 
(excluding names rule-

related) 

 -42,438 hours   -$ 19,479,042 -$20,902,000 

Proposed Amendments to Remove Names Rule-Related Reporting7 

Removal of names 
rule-related reporting 

-19 
hours8 

-16 hours8  $406 -$6,496 -$2,260 

Number of funds  x 9,926 funds   x 9,926 funds x 9,926 

Total new annual 
burden of names rule-
related amendments 

 -158,816 hours8   -$64,479,296 -$22,432,760 

Total Estimated Burdens, Including Proposed Amendments 

Current burden 
estimates 

 2,070,316 hours9    $177,742,893 

Revised burden 
estimates 

 1,869,062 hours    $134,408,133 

Certain products and sums do not tie due to rounding. 

Notes: 

1. Includes initial burden estimates annualized over a 3-year period.  

2. The $459 wage rate reflects current estimates of the blended hourly rate for an accountant and auditor ($348), paralegal and legal 
assistant ($285), and attorney ($744) in the securities industry. To calculate the occupational hourly rates used in this release, the 
Commission uses occupational mean hourly wage data from the Occupational Employment and Wage Statistics (OEWS) program of the 
Bureau of Labor Statistics (BLS) for “Securities, Commodity Contracts, and Other Financial Investments and Related Activities” (NAICS 
523). See Occupational Employment and Wage Statistics, U.S. Bureau of Labor Statistics, https://www.bls.gov/oes/; see also Standard 
Occupational Classification, U.S. Bureau of Labor Statistics, https://bls.gov/soc/ (describing occupational classification system used by 
BLS); Exec. Off. of the President, Off. of Mgmt. & Budget, North American Industry Classification System (2022), available at 
https://www.census.gov/naics/reference_files_tools/2022_NAICS_Manual.pdf (describing the industry classification system used by 
BLS and other agencies). The mean hourly wage for each occupation is adjusted for changes in the seasonally adjusted employment 
cost index for private wages and salaries between the data reference period and when the data are released by BLS. See Employment 
Cost Index, U.S. Bureau of Labor Statistics, https://www.bls.gov/eci/. The adjusted mean hourly wage is then multiplied by a factor that 
accounts for nonwage costs borne by employers, such as bonuses, benefits, and overhead. This factor is calculated as an average over 
the 10 most recently available years of data of the ratio of the Bureau of Economic Analysis’s annual gross output data for NAICS 523 
to total annual wages across all occupations for NAICS 523 in the OEWS data. See Gross Output by Industry, U.S. Bureau of Economic 
Analysis, https://www.bea.gov/data/industries/gross-output-by-industry; Occupational Employment and Wage Statistics, U.S. Bureau 
of labor Statistics, https://wwww.bls.gov/oes/. The final product is the occupational hourly rate. See generally Updated Methodology 

https://www.bls.gov/oes/
https://bls.gov/soc/


99 
 

for Calculating Occupational Hourly Rates (Dec. 19, 2025), available at https://www.sec.gov/files/method-occupational-hourly-
rates.pdf. 

3. In the most recent Form N-PORT PRA submission that was approved in 2024 (OMB Control No. 3235-0730), the added initial burden 
was 6 hours and the added ongoing burden was 5 hours. Relative to that PRA submission, our proposed estimates reflect a reduction 
of initial burden of 3 hours, annualized over a 3-year period, and a reduction of ongoing annual burden of 3 hours. As a result, we are 
retaining an estimated ongoing annual burden of 3 hours per year for filing reports within 45 days of month end, while also accounting 
for the reductions in information that funds would be required to report. This burden estimate is a reduction from the 7 annual burden 
hours estimated in the 2024 Adopting Release. 

4. In the most recent Form N-PORT PRA submission that was approved in 2024 (OMB Control No. 3235-0730), the added external cost 
burden was $41,452,000. Our proposed estimates reflect a reduction of external cost of $1,000 for funds that license a software 
solution to prepare Form N-PORT reports and a reduction of external cost of $2,000 for funds that retain the services of a third-party 
vendor to prepare Form N-PORT reports. This burden estimate is a reduction from the $2,000 and $4,000 external cost burden per 
fund, respectively, estimated in the 2024 Adopting Release. 

5. Based on Commission filings, we estimate that there are 12,668 funds that file reports on Form N-PORT. We estimate that 35% of 
these funds (or 4,434) would license a software solution to prepare Form N-PORT while 65% (or 8,234) would rely on a third-party 
vendor. 

6. In the most recent Form N-PORT PRA submission that was approved in 2024 (OMB Control No. 3235-0730), the added initial burden 
was 6 hours and the added ongoing annual burden was 3 hours. Relative to that PRA submission, our proposed estimates reflect a 
reduction of initial burden of 3 hours, annualized over a 3-year period, and a reduction of ongoing annual burden of 2 hours. As a 
result, we are retaining an estimated ongoing annual burden of 2 hours per year for filing reports within 45 days of month end, while 
also accounting for the reductions in information that funds would be required to report. This burden estimate is a reduction from the 5 
annual burden hours estimated in the 2024 Adopting Release. 

7. In the names rule-related PRA submission that was approved in 2023 (OMB Control No. 3235-0730), the added initial burden was 
12 hours and the added ongoing annual burden was 9 hours for 9,926 funds at an internal cost of $406 and external costs of $2,260 
per fund to report the names rule-related information. We are using the same number of funds, burden hours, wage rates, and external 
costs for these purposes because the Commission has not reassessed the burdens of this reporting since the 2023 names rule 
adoption, and funds have not been required to comply with the names rule-related reporting requirements. If we were to update our 
analysis and use larger or smaller numbers than those used in 2023, this would have unintended effects on the overall PRA estimates 
for Form N-PORT. As an example, larger estimates than those used in 2023 would suggest that removal of these items would not only 
remove the burdens associated with reporting these items, but also have a greater effect on reducing the burdens of Form N-PORT 
reporting.  

8. Due to an error in the names rule-related PRA submission that was approved in 2023 (OMB Control No. 3235-0730), there is a 
discrepancy between the PRA submission and the Commission’s Names Rule Adopting Release with respect to the estimated burden 
hours for names rule-related reporting on Form N-PORT. The burden hour figures in this table are consistent with those the Commission 
estimated in the Names Rule Adopting Release and thus correct the typographical error in the PRA submission.  

9. Because of the correction of the error in the names rule-related PRA submission that was approved in 2023 (OMB Control No. 3235-
0730), the current burden estimate in this table does not align with the current burden estimate in the most recent Form N-PORT PRA 
submission approved in 2024 (OMB Control No. 3235-0730), which reflected an annual internal burden hour estimate of 2,000,834. If 
we instead used the annual internal burden hour estimate approved in 2024, this would have the unintended effect of suggesting that 
removal of the names rule-related reporting would not only remove the burdens associated with reporting these items, but also have a 
greater effect on reducing the burdens of Form N-PORT reporting. 

 

C. Request for Comment 

We request comment on whether these estimates are reasonable. Pursuant to 44 U.S.C. 

3506(c)(2)(B), the Commission solicits comments in order to: (1) evaluate whether the proposed 

collection of information is necessary for the proper performance of the functions of the 

Commission, including whether the information will have practical utility; (2) evaluate the 

accuracy of the Commission’s estimate of the burden of the proposed collection of information, 

including the validity of the methodology and assumptions used; (3) determine whether there are 



100 
 

ways to enhance the quality, utility, and clarity of the information to be collected; and (4) 

determine whether there are ways to minimize the burden of the collection of information on 

those who are to respond, including through the use of appropriate automated, electronic, 

mechanical, or other technological collection techniques or other forms of information 

technology. 

Persons wishing to submit comments on the collection of information requirements of the 

proposed amendments should direct them to the OMB Desk Officer for the Securities and 

Exchange Commission, [email protected], and should send a 

copy to Vanessa A. Countryman, Secretary, Securities and Exchange Commission, 100 F Street 

NE, Washington, DC 20549-1090, with reference to File No. S7-2026-05. OMB is required to 

make a decision concerning the collections of information between 30 and 60 days after 

publication of this release; therefore a comment to OMB is best assured of having its full effect if 

OMB receives it within 30 days after publication of this release. Requests for materials 

submitted to OMB by the Commission with regard to these collections of information should be 

in writing, refer to File No. S7-2026-05, and be submitted to the Securities and Exchange 

Commission, Office of FOIA Services, 100 F Street NE, Washington, DC 20549-2736. 

V. Initial Regulatory Flexibility Analysis 

The Commission has prepared the following Initial Regulatory Flexibility Analysis 

(“IRFA”) in accordance with section 3(a) of the Regulatory Flexibility Act (“RFA”).163 It relates 

to the proposed amendments to Form N-PORT. 

 
163  5 U.S.C. 603(a) 

mailto:[email protected]101 
 

A. Reasons for and Objectives of Proposed Actions 

 The Commission is proposing amendments to reporting requirements on Form N-PORT 

that would provide registered funds with fifteen additional days to file reports, restore the 

quarterly publication frequency, and make modifications to the report form. The objectives of the 

proposed amendments to the filing timeframe and publication frequency are to reduce burden 

and the risk of external parties inferring and using information about a registered fund’s 

proprietary investment strategy or trading intentions in ways that increase costs for fund 

shareholders while maintaining timely Commission access to registered funds’ monthly 

portfolio-related information and providing for appropriate public access to portfolio 

information. The Commission is also proposing amendments to Form N-PORT to streamline or 

remove certain items, to modify how registered funds with share classes that operate as ETFs 

report certain information, and to require additional identifying information. The objectives of 

the proposed amendments to items within Form N-PORT are to refine the information registered 

funds provide while maintaining the usability and reliability of Form N-PORT data. Each of 

these objectives is discussed in detail in section II above. 

B. Legal Basis 

The Commission is proposing the rule and form amendments contained in this document 

under the authority set forth in the Investment Company Act, particularly sections 8, 24, 30, and 

38 thereof [15 U.S.C. 80a-1 et seq.]. 

C. Small Entities Subject to the Amendments 

An investment company is a small entity if, together with other investment companies in 

the same group of related investment companies, it has net assets of $50 million or less as of the 



102 
 

end of its most recent fiscal year.164 Commission staff estimates that, as of December 2024, there 

were 30 open-end management investment companies subject to Form N-PORT reporting 

requirements that would be considered small entities; this number includes 4 open-end ETFs.165 

Commission staff also estimates that, as of December 2024, there were 38 closed-end investment 

management companies that would be considered small entities. All of these small entities would 

be subject to the proposed amendments to the filing timeframe and publication frequency. The 

number of small entities that would be affected by the proposed amendments to the reporting 

items within Form N-PORT would generally depend on the portfolio of each small entity.  

D. Projected Reporting, Recordkeeping, and Other Compliance Requirements 

As finalized in the 2024 amendments, Form N-PORT requires open-end and closed-end 

funds, as well as ETFs organized as UITs, to report monthly portfolio holdings information on a 

monthly basis in a structured, XML format within 30 days after month end. Under the 2024 

amendments, each month’s data will be published 60 days after month end. We propose 

amendments to require these funds to file Form N-PORT reports on a monthly basis within 45 

days after month end and to publish reports for only the third month of a fund’s fiscal quarter 60 

days after month end. We also propose additional amendments to certain items and sub-items on 

Form N-PORT. 

We estimate that 68 open-end and closed-end funds are small entities that would be 

required to comply with our proposed amendments to Form N-PORT. The proposed 

amendments are intended to reduce the risk of errors in the reported information and reduce 

 
164  The Commission has a pending proposal addressing the definition under the Investment Company Act of 

small organization and small business for purposes of the Regulatory Flexibility Act. The Commission 
encourages commenters to review the proposal to determine whether it might affect their comments on this 
IRFA. See Small Entity Proposing Release, supra note 81. 

165  While exchange-traded funds organized as unit investment trusts file Form N-PORT, there are no such 
funds that would be considered small entities. 



103 
 

reporting burdens, while continuing to recognize that Form N-PORT information is most 

valuable to the Commission and staff when it reflects reasonably current portfolio holdings and 

related information. The proposed amendments would also reduce the overall burden on small 

entities by providing fifteen additional days to file Form N-PORT compared to the 2024 

amendments and by streamlining or eliminating certain reporting requirements. We discuss the 

specifics of those burden reductions in the Economic Analysis and Paperwork Reduction Act 

sections above. 

E. Duplicative, Overlapping, or Conflicting Federal Rules 

We do not believe that the proposed amendments would duplicate, overlap, or conflict 

with other existing Federal rules. 

F. Significant Alternatives 

The RFA directs the Commission to consider significant alternatives that would 

accomplish our stated objectives, while minimizing any significant economic impact on small 

entities. We considered the following alternatives for small entities in relation to the proposed 

amendments to Form N-PORT to enhance the benefits of the proposal for small entities: (1) 

establishing different requirements that take into account the resources available to small entities; 

(2) exempting small entities from all or part of the requirements; (3) clarifying, consolidating, or 

simplifying requirements under the rules for small entities; and (4) using performance rather than 

design standards. 

The proposed amendments relating to the filing timeframe are designed to reduce the risk 

of errors in the reported information and reduce reporting burdens, while continuing to recognize 

that Form N-PORT information is most valuable to the Commission and staff when it reflects 

reasonably current portfolio holdings and related information. We anticipate registered funds, 



104 
 

including smaller funds, would benefit from these proposed amendments. We considered 

providing registered funds that are small entities with additional time to file their reports on 

Form N-PORT, such as 60 days after month end. This alternative would further reduce reporting 

costs for registered funds that are small entities. However, delays in the receipt of information 

can affect the Commission’s and the staff’s ability to use Form N-PORT information to carry out 

the Commission’s regulatory function for the asset management industry, and the associated 

benefits of these activities for investors, especially during periods of stress in which analysis of 

potential issues and development of any regulatory responses are particularly time sensitive 

endeavors. For instance, further delaying the receipt of information for registered funds that are 

small entities could hinder the Commission staff’s ability to identify efficiently small funds 

affected in a market stress event. Moreover, delaying the receipt of information for registered 

funds that are small entities would reduce the benefits of receiving more timely information from 

other registered funds, as the information available to the staff would necessarily be incomplete 

until small entities filed at a later date.  

We also considered allowing registered funds that are small entities to make less 

frequent, or more delayed, public disclosure of their portfolio holdings on Form N-PORT. 

However, the costs of an increased publication frequency of portfolio holdings generally relate 

more to a fund’s strategy than its size, so such a change may not significantly benefit registered 

funds that are small entities. Moreover, registered funds that are small entities may be at a lower 

risk for certain types of front running. For example, registered funds that are small entities are 

more likely than other funds to have relatively small position sizes, meaning that it may take 

smaller registered funds less time to build or dispose of positions, which reduces the risk of front 

running. Additionally, all registered fund investors, including investors in funds that are small 



105 
 

entities, benefit from reporting requirements that permit them to make investment choices that 

better match their risk tolerances. Thus, the interest of investors would not be served by 

establishing different Form N-PORT publication requirements for registered funds that are small 

entities. 

The amendments to Form N-PORT’s reporting items would overall reduce reporting 

costs, including for registered funds that are small entities. A few of the amendments would 

amend the reporting threshold of a particular item. Registered funds, including small funds, with 

activity below the reporting threshold would not be required to provide the information. We 

considered higher thresholds for funds that are small entities. While this would further reduce 

costs for these funds, it would result in non-standardized information that is less beneficial to the 

Commission and the public. For example, higher thresholds for small entities would make it 

more difficult to understand interest and credit risks of these funds, as they would have higher 

reporting thresholds for portfolio level risk metrics.  

The proposal would add a few reporting requirements for registered funds with ETF 

share classes. This new reporting would introduce minimal burdens for affected funds. Currently, 

no small entities offer ETF share classes. This could change in the future, and thus we considered 

exempting registered funds that are small entities from these new requirements. Such a change 

would create a minimal burden reduction for small entities if they begin to offer ETF share 

classes. However, an exemption from these requirements would reduce the Commission’s and 

investors’ ability to better understand this growing type of fund structure and to monitor the size 

and flows of different registered funds. 



106 
 

With respect to using performance rather than design standards, the proposed 

amendments primarily use design rather than performance standards to promote more consistent 

and uniform standards for all registered funds. 

G. General Request for Comment 

The Commission requests comments regarding this IRFA. We request comments on the 

number of small entities that may be affected by our proposed amendments and whether the 

proposed amendments would have any effects not considered in this analysis. We request that 

commenters describe the nature of any effects on small entities subject to the rules and forms, 

and provide empirical data to support the nature and extent of such effects. We also request 

comment on the proposed compliance burdens and the effect these burdens would have on 

smaller entities. 

VI. Consideration of Impact on the Economy 

For purposes of Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 

1996 (also known as the Congressional Review Act),166 the Commission must seek OMB’s 

determination whether a final regulation constitutes a “major” rule. Under the Act, a rule is 

considered “major” where, if adopted, it results in or is likely to result in: 

• An annual effect on the economy of $100 million or more;  

• A major increase in costs or prices for consumers or individual industries; or 

• Significant adverse effects on competition, investment, or innovation.167 

To help inform OMB’s determination whether any final rule that results from the 

proposal would be a “major rule,” we solicit comment and data on: 

 
166  See 5 U.S.C. chapter 8. 
167  See 5 U.S.C. 804(2) (defining “major rule”). 



107 
 

• The potential effect on the U.S. economy on an annual basis; 

• Any potential increase in costs or prices for consumers or individual industries; 

and 

• Any potential effect on competition, investment, or innovation. 

Commenters are requested to provide empirical data and other factual support for their 

views to the extent possible.  

VII. Other Matters 

This action is an economically significant regulatory action under section 3(f)(1) of 

Executive Order 12866, as amended, and has been reviewed by the Office of Management and 

Budget. This action, if finalized as proposed, is expected to be an Executive Order 14192 

deregulatory action.  

Statutory Authority 

 The Commission is proposing the rule and form amendments contained in this document 

under the authority set forth in the Investment Company Act, particularly sections 8, 24, 30, and 

38 thereof [15 U.S.C. 80a-1 et seq.]. 

List of Subjects in 17 CFR Parts 270 and 274 

Investment companies, Reporting and recordkeeping requirements, Securities. 

Text of Rule Amendments 

For the reasons stated in the preamble, the Commission proposes to amend 17 CFR parts 

270 and 274 as follows: 

PART 270—RULES AND REGULATIONS, INVESTMENT COMPANY ACT OF 1940 

1. The authority citation for part 270 continues to read, in part, as follows:  



108 
 

Authority: 15 U.S.C. 80a-1 et seq., 80a-34(d), 80a-37, 80a-39, 1681w(a)(1), 6801-6809, 

6825, and Pub. L. 111-203, sec. 939A, 124 Stat. 1376 (2010), unless otherwise noted. 

*  *  *  *  * 

2. Amend § 270.30b1-9 by revising it to read as follows: 

§ 270.30b1-9 Monthly report. 

 Each registered management investment company or exchange-traded fund organized as 

a unit investment trust, or series thereof, other than a registered open-end management 

investment company that is regulated as a money market fund under § 270.2a-7 or a small 

business investment company registered on Form N-5 (§§ 239.24 and 274.5 of this chapter), 

must file a monthly report of portfolio holdings on Form N-PORT (§ 274.150 of this chapter), 

current as of the last business day, or last calendar day, of the month. A registered investment 

company that has filed a registration statement with the Commission registering an offering of its 

securities for the first time under the Securities Act of 1933 is relieved of this reporting 

obligation with respect to any reporting period or portion thereof prior to the date on which that 

registration statement becomes effective or is withdrawn. Reports on Form N-PORT must be 

filed with the Commission no later than 45 days after the end of each month. If a registered 

investment company does not file monthly reports within 45 days after the end of each month in 

accordance with the transition period described in Investment Company Act Release No. 35962 

(Feb. 18, 2026), it must maintain in its records the information that is required to be included on 

Form N-PORT no later than 30 days after the end of each month. Such information shall be 

treated as a record under section 31(a)(1) of the Act [15 U.S.C. 80a30(a)(1)] and § 270.31a-1(b) 

subject to the requirements of § 270.31a-2(a)(2). 

§ 270.30b1-9 [Amended] 



109 
 

 3. Effective 18 months after publication of final rules in the Federal Register, further 

amend § 270.30b1-9 by removing the last two sentences. 

PART 274—FORMS PRESCRIBED UNDER THE INVESTMENT COMPANY ACT OF 

1940 

4. The general authority citation for part 274 continues to read, in part, as follows:  

 Authority: 15 U.S.C. 77f, 77g, 77h, 77j, 77s, 78c(b), 78l, 78m, 78n, 78n-1, 78o(d), 80a-

8, 80a-24, 80a-26, 80a-29, and sec. 939A, Pub. L. 111-203, 124 Stat. 1376, unless otherwise 

noted. 

* * * * * 

5. Amend § 274.150 by revising paragraph (a) to read as follows: 

§ 274.150 Form N–PORT, Monthly portfolio holdings report. 

 (a) Except as provided in paragraph (b) of this section, this form shall be used by 

registered management investment companies or exchange-traded funds organized as unit 

investment trusts, or series thereof, to file reports pursuant to § 270.30b1–9 of this chapter no 

later than 45 days after the end of each month.  

* * * * * * 

6. Amend Form N-PORT (referenced in § 274.150) by: 

a. Revising General Instructions A, E, and F; 

b. Redesignating current Item A.3 as Item A.4 and Item A.4 as Item A.5; 

c. Adding new Item A.3; 

d. Revising Items B.1, B.3, B.5, and B.6; 

e. Removing Item B.11; 

f. Revising Item C.2; 



110 
 

g. Removing and reserving Item C.3; and 

h. Revising Item C.7, Item C.9, and Part D. 

Note: Form N-PORT is attached as Appendix A to this document. Form N-PORT will not 

appear in the Code of Federal Regulations.   

By the Commission. 

Dated: February 18, 2026. 

 

 

Vanessa A. Countryman,  

Secretary. 

Note: The following appendix will not appear in the Code of Federal Regulations. 

  



111 
 

Appendix A–Form N-PORT 

FORM N-PORT 

* * * * * 

GENERAL INSTRUCTIONS 

A. Rule as to Use of Form N-PORT  

 Form N-PORT is the reporting form that is to be used for monthly reports of Funds other 

than money market funds and SBICs under section 30(b) of the Act, as required by rule 30b1-9 

under the Act (17 CFR 270.30b1-9). Funds must report information about their portfolios and 

each of their portfolio holdings as of the last business day, or last calendar day, of each month. A 

registered investment company that has filed a registration statement with the Commission 

registering an offering of its securities for the first time under the Securities Act of 1933 is 

relieved of this reporting obligation with respect to any reporting period or portion thereof prior 

to the date on which that registration statement becomes effective or is withdrawn. 

Reports on Form N-PORT must disclose portfolio information as calculated by the fund 

for the reporting period’s ending net asset value (commonly, and as permitted by rule 2a-4, the 

first business day following the trade date). Reports on Form N-PORT for each month must be 

filed with the Commission no later than 45 days after the end of such month. If the due date falls 

on a weekend or holiday, the filing deadline will be the next business day.  

A Fund may file an amendment to a previously filed report at any time, including an 

amendment to correct a mistake or error in a previously filed report. A Fund that files an 

amendment to a previously filed report must provide information in response to all items of 

Form N-PORT, regardless of why the amendment is filed. 

* * * * * 



112 
 

E. Definitions 

References to sections and rules in this Form N-PORT are to the Act, unless otherwise 

indicated.  Terms used in this Form N-PORT have the same meanings as in the Act or related 

rules (including rule 18f-4 solely for Items B.9 and 10 of the Form), unless otherwise indicated.  

As used in this Form N-PORT, the terms set out below have the following meanings:  

“Absolute VaR Test” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Class” means a class of shares issued by a Fund that has more than one class that 

represents interests in the same portfolio of securities under rule 18f-3 [17 CFR 270.18f-3] or 

under an order exempting the Fund from provisions of section 18 of the Act [15 U.S.C. 80a-18]. 

“Controlled Foreign Corporation” has the meaning provided in section 957 of the Internal 

Revenue Code [26 U.S.C. 957]. 

“Derivatives Exposure” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Designated Index” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Designated Reference Portfolio” has the meaning defined in rule 18f-4(a) [17 CFR 

270.18f-4(a)] 

“Exchange-Traded Fund” means an open-end management investment company (or 

Series or Class thereof) or unit investment trust (or series thereof), the shares of which are listed 

and traded on a national securities exchange at market prices, and that has formed and operates 

under an exemptive order under the Act granted by the Commission or in reliance on rule 6c-11 

[17 CFR 270.6c-11].  

“ETF Class” means a Class that is an Exchange-Traded Fund in a Multiple Class Fund.  

“Fund” means the Registrant or a separate Series of the Registrant.  When an item of 

Form N-PORT specifically applies to a Registrant or a Series, those terms will be used.  



113 
 

“Highly Liquid Investment Minimum” has the meaning defined in rule 22e-4(a)(7) [17 CFR 

270.22e-4(a)(7)]. 

“Illiquid Investment” has the meaning defined in rule 22e-4(a)(8) [17 CFR 270.22e-

4(a)(8)].  

“ISIN” means, with respect to any security, the “international securities identification 

number” assigned by a national numbering agency, partner, or substitute agency that is 

coordinated by the Association of National Numbering Agencies.  

“LEI” means, with respect to any company, the “legal entity identifier” as assigned by a 

utility endorsed by the Global LEI Regulatory Oversight Committee or accredited by the Global 

LEI Foundation.   

“Multiple Class Fund” means a Fund that has more than one Class. 

“Registrant” means a management investment company, or an Exchange-Traded Fund 

organized as a unit investment trust, registered under the Act. 

“Relative VaR Test” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Restricted Security” has the meaning defined in rule 144(a)(3) under the Securities Act of 1933 

[17 CFR 230.144(a)(3)]. 

“RSSD ID” means the identifier assigned by the National Information Center of the 

Board of Governors of the Federal Reserve System, if any. 

“Securities Portfolio” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Series” means shares offered by a Registrant that represent undivided interests in a 

portfolio of investments and that are preferred over all other series of shares for assets 

specifically allocated to that series in accordance with rule 18f-2(a) [17 CFR 270.18f-2(a)].  



114 
 

“Swap” means either a “security-based swap” or a “swap” as defined in sections 3(a)(68) 

and (69) of the Securities Exchange Act of 1934 [15 U.S.C. 78c(a)(68) and (69)] and any rules, 

regulations, or interpretations of the Commission with respect to such instruments.  

“Value-at-Risk” or VaR has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“VaR Ratio” means the value of the Fund’s portfolio VaR divided by the VaR of the 

Designated Reference Portfolio. 

F. Public Availability 

 Information reported on Form N-PORT for the third month of each Fund’s fiscal quarter 

will be made publicly available 60 days after the end of the Fund’s fiscal quarter. 

 The SEC does not intend to make public the information reported on Form N-PORT for 

the first and second months of each Fund’s fiscal quarter that is identifiable to any particular 

fund or adviser, or any information reported with respect to a Fund’s Highly Liquid Investment 

Minimum (Item B.7), derivatives transactions (Item B.8), Derivatives Exposure for limited 

derivatives users (Item B.9), median daily VaR (Item B.10.a), median VaR Ratio (Item 

B.10.b.iii), VaR backtesting results (Item B.10.c), country of risk and economic exposure (Item 

C.5.b), delta (Items C.11.c.vii or C.11.g.iv), liquidity classification for portfolio investments 

(Item C.7), or miscellaneous securities (Part D), or explanatory notes related to any of those 

topics (Part E) that is identifiable to any particular fund or adviser. However, the SEC may use 

information reported on this Form in its regulatory programs, including examinations, 

investigations, and enforcement actions. 

* * * * * 

Item A.3. Ticker Information 

a. Ticker symbol of Registrant, if any. 



115 
 

b. For each Class of Registrant or Series, as applicable, the:  

i. EDGAR Class identification number;  

ii. Class name; and  

iii. Ticker symbol. 

* * * * * 

Item B.1. Assets and liabilities.  Report amounts in U.S. dollars. 

* * * * *  

d. If the Fund is a Multiple Class Fund with an ETF Class, also provide the ETF Class’s 

ticker symbol and the information required by Item B.1.c separately for the ETF Class. 

* * * * *  

Item B.3. Portfolio level risk metrics.  If the average value of the Fund’s debt securities 

positions for the previous three months, in the aggregate, exceeds 50% of the Fund’s net asset 

value, provide: 

a. Interest Rate Risk (DV100).  Provide the change in value of the portfolio resulting from a 

100 basis point change in interest rates, aggregated across all currencies for which the 

Fund had a value of 1% or more of the Fund’s net asset value, for each of the following 

maturities: 3 month, 1 year, 5 years, 10 years, and 30 years. 

b. Credit Spread Risk (SDV01, CR01 or CS01).  Provide the change in value of the 

portfolio resulting from a 1 basis point change in credit spreads where the shift is applied 

to the option adjusted spread for each of the following maturities:  3 month, 1 year, 5 

years, 10 years, and 30 years. 

For purposes of Item B.3., calculate value as the sum of the absolute values of:  (i) the value 

of each debt security, (ii) the notional value of each swap, including, but not limited to, total 



116 
 

return swaps, interest rate swaps, and credit default swaps, for which the underlying 

reference asset or assets are debt securities or an interest rate; (iii) the notional value of each 

futures contract for which the underlying reference asset or assets are debt securities or an 

interest rate; and (iv) the delta-adjusted notional value of any option for which the underlying 

reference asset is an asset described in clause (i),(ii), or (iii).  Report zero for maturities to 

which the Fund has no exposure.  For exposures that fall between any of the listed maturities 

in (a) and (b), use linear interpolation to approximate exposure to each maturity listed above. 

For exposures outside of the range of maturities listed above, include those exposures in the 

nearest maturity. Report in U.S. dollars.  

* * * * *  

Item B.5. Return information.   

a. Monthly total returns of the Fund for each of the preceding three months.  If the Fund is a 

Multiple Class Fund, report returns for a single representative Class.  Such returns shall 

be calculated in accordance with the methodologies outlined in Item 26(b)(1) of Form N-

1A, Instruction 13 to sub-Item 1 of Item 4 of Form N-2, or Item 26(b)(i) of Form N-3, as 

applicable, except the return calculation should not deduct sales loads and redemption 

fees charged to shareholder accounts. 

b. Class identification number (if any) of the representative Class for which returns are 

reported.   

c. For each of the preceding three months, monthly net realized gain (loss) and net change 

in unrealized appreciation (or depreciation) attributable to derivatives for each of the 

following asset categories:  commodity contracts, credit contracts, equity contracts, 



117 
 

foreign exchange contracts, interest rate contracts, and other contracts.  Report in U.S. 

dollars.  Losses and depreciation shall be reported as negative numbers.  

d. For each of the preceding three months, monthly net realized gain (loss) and net change 

in unrealized appreciation (or depreciation) attributable to investments other than 

derivatives.  Report in U.S. dollars.  Losses and depreciation shall be reported as negative 

numbers.  

Instruction to Item B.5. For a Multiple Class Fund, select the representative Class in the 

same manner as described in Instruction 3(a) to Item 4(b)(2) of Form N-1A. 

Item B.6. Flow information.  Provide the aggregate dollar amounts for sales and 

redemptions/repurchases of Fund shares during each of the preceding three months.  If shares of 

the Fund are held in omnibus accounts, for purposes of calculating the Fund’s sales, 

redemptions, and repurchases, use net sales or redemptions/repurchases from such omnibus 

accounts.  The amounts to be reported under this Item should be after any front-end sales load 

has been deducted and before any deferred or contingent deferred sales load or charge has been 

deducted.  Shares sold shall include shares sold by the Fund to a registered unit investment trust.  

For mergers and other acquisitions, include in the value of shares sold any transaction in which 

the Fund acquired the assets of another investment company or of a personal holding company in 

exchange for its own shares.  For liquidations, include in the value of shares redeemed any 

transaction in which the Fund liquidated all or part of its assets.  Exchanges are defined as the 

redemption or repurchase of shares of one Fund or series and the investment of all or part of the 

proceeds in shares of another Fund or series in the same family of investment companies.   

* * * * * 



118 
 

d. If the Fund is a Multiple Class Fund with an ETF Class, also provide the information 

required by Item B.6.a through B.6.c separately for the ETF Class. 

* * * * * 

Item C.2. Amount of each investment. 

a. Balance.  Indicate whether amount is expressed in number of shares, principal amount, or 

other units.  For derivatives contracts, as applicable, provide the number of contracts. 

b. Currency.  Indicate the currency in which the investment is denominated. 

c. Value.  Report values in U.S. dollars.  If currency of investment is not denominated in 

U.S. dollars, provide the exchange rate used to calculate value. 

d. Percentage value compared to net assets of the Fund. 

Item C.3. [Reserved] 

* * * * * 

Item C.7. Liquidity classification information.  For portfolio investments of open-end 

management investment companies, provide the liquidity classification(s) for each portfolio 

investment among the following categories as specified in rule 22e-4 [17 CFR 270.22e-4]. For 

portfolio investments with multiple liquidity classifications, indicate the percentage amount 

attributable to each classification.  

a.  Highly Liquid Investments  

b. Moderately Liquid Investments  

c. Less Liquid Investments  

d. Illiquid Investments 



119 
 

Instructions to Item C. 7 Funds may choose to indicate the percentage amount of a holding 

attributable to multiple classification categories only in the following circumstances: (1) if 

portions of the position have differing liquidity features that justify treating the portions 

separately; (2) if a fund has multiple sub-advisers with differing liquidity views; or (3) if the 

fund chooses to classify the position through evaluation of how long it would take to 

liquidate the entire position (rather than basing it on the sizes it would reasonably 

anticipated trading). In (1) and (2), a fund would classify using the reasonably anticipated 

trade size for each portion of the position.  

* * * * * 

Item C.9. For debt securities, also provide: 

* * * * * 

f.  For convertible securities, also provide: 

i. Mandatory convertible?  [Y/N] 

ii. Contingent convertible?  [Y/N] 

iii. Description of the reference instrument, including the name of issuer, title of issue, 

and currency in which denominated, as well as CUSIP of reference instrument, ISIN 

(if CUSIP is not available), ticker (if CUSIP and ISIN are not available), or other 

identifier (if CUSIP, ISIN, and ticker are not available).  If other identifier provided, 

indicate the type of identifier used. 

* * * * * 

Part D: Miscellaneous Securities 



120 
 

For reports filed for the last month of each fiscal quarter, report miscellaneous securities, if any, 

using the same Item numbers and reporting the same information that would be reported for each 

investment in Part C if it were not a miscellaneous security.  Information reported in this Item 

will be nonpublic. 

* * * * *

1 

SECURITIES AND EXCHANGE COMMISSION 

17 CFR Parts 270 and 274 

[Release No. IC-35962; File No. S7-2026-05] 

RIN 3235-AN44 

Form N-PORT Reporting 

AGENCY: Securities and Exchange Commission.  

ACTION: Proposed rule. 

SUMMARY: The Securities and Exchange Commission (the “Commission”) is proposing 

amendments to reporting requirements on Form N-PORT that apply to certain registered 

investment companies, including registered open-end funds, registered closed-end funds, and 

exchange-traded funds organized as unit investment trusts. The proposed amendments would 

modify provisions adopted in 2024 to provide these funds with an additional fifteen days to file 

monthly reports of portfolio-related information on Form N-PORT and would restore the 

quarterly publication frequency that had been in place for over two decades. The Commission is 

proposing these amendments in light of feedback from market participants and other 

developments. The Commission is also proposing to streamline or remove certain items and sub-

items, reducing reporting burdens in ways that would not significantly affect the Commission’s 

uses of the data and are not expected to significantly affect the public’s ability to assess relevant 

information about a fund. Finally, the Commission is proposing to adjust how funds with share 

classes that operate as exchange-traded funds report certain information to improve information 

about this fund structure and to require information about funds’ ticker symbols, as well as 

certain class-level identifiers, as applicable, to facilitate efficient use of the reported information. 

DATES: Comments should be submitted on or before April 24, 2026. 

Conformed to Federal Register version



2 
 

ADDRESSES: Comments may be submitted by any of the following methods: 

Electronic Comments: 

• Use the Commission’s internet comment form (https://www.sec.gov/comments/s7-2026-

05/form-n-port-reporting); or  

• Send an email to [email protected]. Please include File Number S7-2026-05 on 

the subject line. 

Paper Comments: 

• Send paper comments to Secretary, Securities and Exchange Commission, 100 F Street 

NE, Washington, DC 20549-1090. 

All submissions should refer to File Number S7-2026-05. This file number should be 

included on the subject line if email is used. To help the Commission process and review your 

comments more efficiently, please use only one method of submission. The Commission will 

post all comments on the Commission’s website (https://www.sec.gov/comments/s7-2026-

05/form-n-port-reporting). Do not include personal identifiable information in submissions; you 

should submit only information that you wish to make available publicly. We may redact in part 

or withhold entirely from publication submitted material that is obscene or subject to copyright 

protection. 

Studies, memoranda, or other substantive items may be added by the Commission or staff 

to the comment file during this rulemaking. A notification of the inclusion in the comment file of 

any such materials will be made available on the Commission’s website. To ensure direct 

electronic receipt of such notifications, sign up through the “Stay Connected” option at 

www.sec.gov to receive notifications by email. 

https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting
https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting
https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting
https://www.sec.gov/comments/s7-2026-05/form-n-port-reporting


3 
 

A summary of the proposal of not more than 100 words is posted on the Commission’s 

website (https://www.sec.gov/rules-regulations/2026/02/s7-2026-05). 

FOR FURTHER INFORMATION CONTACT: Susan Ali, Counsel; Angela Mokodean, 

Senior Special Counsel; or Brian M. Johnson, Assistant Director at (202) 551-6792, Investment 

Company Regulation Office, Division of Investment Management, Securities and Exchange 

Commission, 100 F Street NE, Washington, DC 20549-8549. 

SUPPLEMENTARY INFORMATION: The Commission is proposing amendments to 17 

CFR 270.30b1-9 (“rule 30b1-9”), 17 CFR 274.150, and Form N-PORT [referenced in 17 CFR 

274.150] under the Investment Company Act of 1940 (the “Act”). 

TABLE OF CONTENTS 

I. Introduction ................................................................................................................... 4 
A. Developments after Adoption of the 2024 Amendments ........................................... 6 
B. Overview of Proposed Amendments .......................................................................... 8 

II. Discussion..................................................................................................................... 11 
A. Filing Timeframe ...................................................................................................... 11 
B. Publication Frequency .............................................................................................. 25 
C. Other Proposed Amendments to Form N-PORT ...................................................... 36 
D. Proposed Transition Period ....................................................................................... 60 

III. Economic Analysis ...................................................................................................... 63 
A. Introduction ............................................................................................................... 63 
B. Baseline ..................................................................................................................... 65 

1. Regulatory Baseline .......................................................................................... 66 
2. Affected Entities ............................................................................................... 68 
3. Economic Literature on the Disclosure of Registered Fund Portfolio Holdings

 72 
C. Benefits and Costs of the Amendments .................................................................... 74 

1. Filing Timeframe .............................................................................................. 74 
2. Publication Frequency ...................................................................................... 76 
3. Other Proposed Amendments to Form N-PORT .............................................. 79 
4. Monetized Benefits and Costs .......................................................................... 84 

https://www.sec.gov/rules-regulations/2026/02/s7-2026-05


4 
 

5. Present Values and Annualized Values of Monetized Benefits and Costs ....... 86 
D. Effects on Efficiency, Competition, and Capital Formation ..................................... 89 

1. Efficiency .......................................................................................................... 89 
2. Competition....................................................................................................... 91 
3. Capital Formation ............................................................................................. 91 

E. Reasonable Alternatives............................................................................................ 92 
1. Filing Timeframe .............................................................................................. 92 
2. Publication of Registered Fund Holdings ......................................................... 93 

IV. Paperwork Reduction Act .......................................................................................... 94 
A. Introduction ............................................................................................................... 94 
B. Form N-PORT .......................................................................................................... 95 
C. Request for Comment ............................................................................................... 99 

V. Initial Regulatory Flexibility Analysis .................................................................... 100 
A. Reasons for and Objectives of Proposed Actions ................................................... 101 
B. Legal Basis .............................................................................................................. 101 
C. Small Entities Subject to the Amendments ............................................................. 101 
D. Projected Reporting, Recordkeeping, and Other Compliance Requirements ......... 102 
E. Duplicative, Overlapping, or Conflicting Federal Rules ........................................ 103 
F. Significant Alternatives .......................................................................................... 103 
G. General Request for Comment................................................................................ 106 

VI. Consideration of Impact on the Economy .............................................................. 106 
VII. Other Matters ........................................................................................................ 107 
Statutory Authority ............................................................................................................ 107 

 

I. Introduction  

 On August 28, 2024, the Commission adopted amendments to Form N-PORT to require 

more frequent reporting of monthly portfolio holdings and related information to the 

Commission and the public, and to modify certain reporting requirements relating to entity 



5 
 

identifiers (the “2024 amendments”).1 Many registered investment companies are required to 

report on Form N-PORT, including registered open-end funds, registered closed-end funds, and 

exchange-traded funds (“ETFs”) organized as unit investment trusts, but excluding money 

market funds and small business investment companies (hereinafter, registered investment 

companies that are required to report on Form N-PORT are referred to as “registered funds”). 

Reports on Form N-PORT provide monthly information about a registered fund’s complete 

portfolio holdings, as well as related information to help assess a fund’s risks, including 

investment risk (e.g., interest rate risk, credit risk, and volatility risk), liquidity risk, counterparty 

risk, and leverage. These reports are an important source of information for the Commission and 

its staff in carrying out regulatory responsibilities related to registered funds and the broader 

asset management industry. Overall, the 2024 amendments were intended to provide the 

Commission and the public with timelier information about funds’ portfolio investments, 

enabling more comprehensive oversight of an ever-evolving registered fund industry by the 

Commission and providing investors with information to make more informed investment 

decisions. 

As discussed in more detail below, several developments occurred following the adoption 

of the 2024 amendments. As a result, the Commission has delayed the effective and compliance 

dates of the 2024 amendments and reviewed those amendments and their possible effects, as set 

forth in this release. In connection with that review, we are proposing to provide funds with 

fifteen additional days to file monthly reports with the Commission. This additional time is 

 
1  Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management 

Programs, Investment Company Act Release No. 35308 (Aug. 28, 2024) [89 FR 73764 (Sept. 11, 2024)] 
(“2024 Adopting Release”), https://www.sec.gov/files/rules/final/2024/ic-35308.pdf. The Commission also 
adopted amendments to Form N-CEN and provided guidance on liquidity risk management program 
requirements for open-end funds. Those aspects of the 2024 Adopting Release are not affected by this 
proposal. 



6 
 

designed to reduce the risk of errors in the reported information and reduce reporting burdens 

while continuing to recognize that Form N-PORT information is more valuable to the 

Commission and staff when it reflects more current portfolio holdings and related information. 

Additionally, to reduce the risk associated with the 2024 amendments that external parties may 

use more frequent disclosures of a registered fund’s portfolio holdings to infer the fund’s 

proprietary investment strategy or trading intentions and use that information in ways that 

increase costs for the fund and its shareholders, and in light of advancements in technology, we 

are proposing to revert to providing the public with access to quarterly snapshots of portfolio 

information on Form N-PORT, consistent with requirements for the past two decades prior to the 

adoption of the 2024 amendments.2  

The Commission is also proposing to remove or streamline certain items and sub-items of 

the form to refine the information that is collected without significantly affecting the utility of 

the reported information. In addition, we are proposing to require registered funds with share 

classes that operate as exchange-traded funds (“ETF share classes”) to report certain information 

on the form to improve the Commission’s and the public’s understanding of the size and flows of 

this type of fund structure. Finally, we are proposing to require registered funds to report certain 

additional identifying information, such as ticker symbols, to help data users use the reported 

information more efficiently. 

A. Developments after Adoption of the 2024 Amendments 

Following adoption of the 2024 amendments, several developments caused the 

Commission to delay the effective and compliance dates of the 2024 amendments and review 

 
2  See Shareholder Reports and Quarterly Portfolio Disclosure of Registered Investment Companies, 

Investment Company Act Release No. 26372 (Feb. 27, 2004) [69 FR 11244 (Mar. 9, 2004)] (“Shareholder 
Reports and Quarterly Portfolio Disclosure Release”). 



7 
 

their potential effects.3 In October 2024, petitioner Registered Funds Association filed a petition 

in the Fifth Circuit Court of Appeals seeking review of the 2024 amendments.4 Although the 

petitioner challenged the Form N-PORT amendments as a whole, it emphasized concerns related 

to more frequent publication of registered funds’ portfolio holdings. These proceedings are 

currently stayed while the Commission reviews the 2024 amendments and considers potential 

changes.5  

 Additionally, on January 20, 2025, President Donald J. Trump signed a Presidential 

Memorandum directing agencies to consider postponing the effective date for any rules that had 

been issued but had not yet taken effect for the purpose of reviewing any questions of fact, law, 

and policy that the rules may raise.6 The Presidential Memorandum further states that, for those 

rules that raise substantial questions of fact, law, or policy, agencies should take further 

appropriate action. Moreover, the President subsequently issued additional Executive Orders 

expressing a policy goal of reducing regulatory burdens.7 At the time of the signing of the 

Presidential Memorandum, the 2024 amendments, while issued, had not yet taken effect. As a 

 
3  Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management 

Programs; Delay of Effective and Compliance Dates, Investment Company Act Release No. 35538 (Apr. 
16, 2025) [90 FR 16812 (Apr. 22, 2025)] (“2025 Delay Release”), 
https://www.sec.gov/files/rules/final/2025/ic-35538.pdf. Specifically, the Commission delayed the effective 
date for the Form N-PORT amendments from Nov. 17, 2025, to Nov. 17, 2027, and delayed the compliance 
date from Nov. 17, 2025, to Nov. 17, 2027, for larger entities and from May 18, 2026, to May 18, 2028, for 
smaller entities. 

4  Registered Funds Association v. SEC, No. 24-60550 (5th Cir. 2024). 
5  See ECF No. 50-2, Registered Funds Association v. SEC, No. 24-60550 (5th Cir. Feb. 11, 2025). 
6  Regulatory Freeze Pending Review (Jan. 20, 2025) [90 FR 8249 (Jan. 28, 2025)], available at 

https://www.whitehouse.gov/presidential-actions/2025/01/regulatory-freeze-pending-review/ (“Presidential 
Memorandum”). The Presidential Memorandum directed agencies to consider postponing the effective date 
of any such rules for 60 days and, as appropriate and consistent with applicable law, and where necessary 
to continue to review the questions of fact, law, and policy, consider further delaying, or publishing for 
notice and comment proposed rules further delaying such rules, beyond the 60-day period. 

7  See, e.g., Unleashing Prosperity Through Deregulation (Jan. 31, 2025) [90 FR 9065 (Feb. 6, 2025)], 
available at https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-prosperity-through-
deregulation/. 



8 
 

result, the Commission initiated a review of the 2024 amendments to consider questions of fact, 

law, or policy associated with the amendments. While performing the review, we also considered 

other aspects of Form N-PORT and the overall effectiveness and usability of information 

reported on the form. 

 Since the adoption of the 2024 amendments, the Commission also has received additional 

feedback on the amendments, including through staff outreach, to inform our review of the 

amendments. Through letters and meetings, registered fund industry members have further 

highlighted and provided additional information about the potential negative impacts of the 

amendments as industry members began to focus on implementation. For example, industry 

members have indicated that the 30-day reporting timeframe requires registered funds to gather 

data more quickly than current operational processes contemplate and to accelerate internal 

review and signoff procedures, which we understand is particularly difficult for certain funds 

with more complex strategies, and increases the overall risk of errors and resubmissions. 

Additionally, a letter from a registered fund industry group suggested that the amendments 

would also harm registered fund shareholders and curb fund innovation and suggested that the 

Commission amend its approach.8  

B. Overview of Proposed Amendments 

 As part of the Commission’s review of the Form N-PORT amendments, we have 

considered available information, including additional information and evolving dynamics 

following the adoption of the amendments, and accordingly have reassessed the benefits and 

costs of the amendments. As a result of this review, we are proposing to extend the filing 

 
8  See Letter from Investment Company Institute (Feb. 26, 2025) (“ICI Letter”), available at 

https://www.ici.org/system/files/2025-02/25-cl-form%20nport-amendments.pdf. 



9 
 

deadline from 30 to 45 days after month end and are proposing to publish reports for only the 

third month of a registered fund’s fiscal quarter 60 days after month end. Table 1 below displays 

the key elements of the Form N-PORT requirements that were revised as a part of the 2024 

amendments and compares the previous Form N-PORT requirements, the 2024 amendments, and 

the current proposal.9    

Table 1. Comparison of Form N-PORT Requirements Prior to 2024 Amendments, the 

2024 Amendments, and the Proposed Amendments 

 Requirements Prior 
to 2024 

Amendments1 

2024 Amendments Proposed 
Amendments 

Filing Timeframe Reports for each 
month in a registered 
fund’s fiscal quarter 
must be filed no later 
than 60 days after the 
end of the relevant 
fiscal quarter 

Reports for each 
month must be filed 
no later than 30 days 
after the end of the 
relevant month 

Reports for each 
month must be filed 
no later than 45 days 
after the end of the 
relevant month 

Publication 
Frequency 

Information reported 
for the third month of 
a registered fund’s 
fiscal quarter will be 
made public upon 
filing (i.e., no later 
than 60 days after 
fiscal quarter end) 

Information reported 
for each month will 
be made public 60 
days after month end 

Information reported 
for the third month of 
a registered fund’s 
fiscal quarter will be 
made public 60 days 
after fiscal quarter 
end 

Recordkeeping  No later than 30 days 
after the end of each 
month, a registered 
fund must maintain in 
its records the 
information that 
Form N-PORT 
requires  

N/A N/A 

Entity Identifiers Certain items require 
reporting of a legal 
entity identifier 

Provides separate 
fields for reporting 

No change to 2024 
amendments. 

 
9  For a table displaying the key proposed changes to the information registered funds are required to report 

on Form N-PORT, see infra section II.C, Table 2. 



10 
 

(“LEI”), if any, of a 
counterparty or 
issuer. If an LEI has 
not been assigned, 
registered funds 
instead provide in the 
LEI field an RSSD 
ID, if any, assigned 
by the National 
Information Center of 
the Board of 
Governors of the 
Federal Reserve 
System. 

LEI or RSSD ID, if 
any. 

Notes: 
 
1. The requirements described in this column are currently in effect and reflect the approach that registered funds 
currently are required to follow, as the effective date of the 2024 amendments has been delayed until November 
17, 2027. 

 

The proposed amendments would continue to provide the Commission with reasonably 

timely data while also reducing operational burdens and the risk of errors. In addition, compared 

to the 2024 amendments, the proposed quarterly publication schedule is designed to reduce the 

risk of external parties inferring a registered fund’s proprietary trading strategy or trading 

intentions from Form N-PORT reports and acting on that information in a way that is harmful to 

the fund. We are soliciting public comment on whether the proposed changes strike an 

appropriate balance between the benefits of portfolio-related information for the Commission 

and the public and the burdens to registered funds of reporting such information. 

Separate from the proposed changes to the filing timeframe and publication frequency of 

Form N-PORT reports, we are proposing to modify certain information collected on portfolio 

level risk metrics and returns to narrow their scope, and proposing to eliminate certain 

information collected on non-derivatives instruments’ payoff profiles, convertible bonds, and the 

reason a single holding has multiple liquidity classifications. In addition, we are proposing to 



11 
 

remove the reporting requirements added to Form N-PORT when the Commission adopted 

amendments to rule 35d-1 under the Act (the “names rule”).10 The proposed amendments to 

streamline or remove reporting requirements would not significantly affect the Commission’s 

uses of the data and are not expected to significantly affect the public’s ability to assess relevant 

information about a registered fund, but would reduce the reporting burden for these funds.  

Finally, we are proposing to require certain additional information. We propose to require 

a registered fund with an ETF share class to report information on the ETF class’s net assets and 

shareholder flows. These amendments are designed to provide the Commission and investors 

with information to better understand the size and flows of this type of fund structure. We also 

propose to require registered funds to provide information about their ticker symbols, as well as 

certain class-level identifiers, as applicable. These amendments are designed to help data users 

more efficiently use other information that is reported on the form.   

II. Discussion 

A. Filing Timeframe  

 We are proposing to amend rule 30b1-9 and Form N-PORT to require registered funds to 

file Form N-PORT reports within 45 days after the end of the month to which they relate.11 

Specifically, rather than filing monthly reports with the Commission within 60 days after the end 

of each fiscal quarter consistent with the prior rule or within 30 days after the end of each 

calendar month as required under the 2024 amendments, we are proposing to require registered 

funds file reports on a monthly basis within 45 days after the end of the month to which they 

 
10  See Investment Company Names, Investment Company Act Release No. 35000 (Sept. 20, 2023) [88 FR 

70436 (Oct. 11, 2023)], Investment Company Names; Correction, Investment Company Act Release No. 
35000A (Oct. 24, 2023) [88 FR 73755 (Oct. 27, 2023)] (“Names Rule Adopting Release”). Funds have not 
begun to comply with the names rule-related reporting requirements on Form N-PORT. 

11  See General Instruction A of proposed Form N-PORT; proposed rule 30b1-9. We are also proposing 
conforming amendments to 17 CFR 274.150. 



12 
 

relate. These proposed changes are intended to better balance the need for the Commission to 

receive timely data against burdens to registered funds relative to the 2024 amendments. 

Specifically, the proposed approach would provide registered funds with an additional 15 days to 

gather, verify, and file information relative to the 30-day filing requirement in the 2024 

amendments. 

 As a general matter, the Commission and its staff use information in Form N-PORT 

reports to carry out regulatory responsibilities related to registered funds, and investors benefit 

indirectly from the Commission’s use of Form N-PORT information. For instance, the 

Commission and staff use Form N-PORT information for purposes of examination, enforcement, 

and monitoring of registered funds, including assessing regulatory compliance, identifying funds 

for examination, and risk monitoring. Form N-PORT reports also provide the Commission 

information that is useful to understand trends in the registered fund industry and to inform and 

formulate regulatory policy. Further, the Commission uses Form N-PORT information in 

connection with its review of fund registration statements and disclosures (e.g., by considering a 

fund’s portfolio holdings in relation to its disclosures). Finally, in the case of market events, the 

Commission uses Form N-PORT information to help assess the breadth and magnitude of the 

potential impacts of such events (e.g., to analyze registered funds’ potential exposures to issuers 

or asset classes that are under stress due to market events). 

 When the Commission adopted the 2024 requirement to file monthly reports within 30 

days of month end, it acknowledged tradeoffs in how frequently and quickly registered funds 

must file Form N-PORT information. While more frequent and timely filings enhance the 

Commission staff’s ability to oversee and monitor registered funds’ activities (as the information 

is more likely to reflect reasonably current portfolio information), it also increases costs, the 



13 
 

potential for errors in filed information and, for funds that do not voluntarily publicly disclose 

their portfolio holdings on a more frequent basis, increases the sensitivity of the filed information 

and the associated risk of misappropriation in the event of a system breach.12 As part of our 

review, we reconsidered these tradeoffs, accounting for additional information from registered 

funds’ preliminary implementation efforts, comments submitted in connection with the 2024 

amendments, and the Commission’s need for and uses of information contained in Form N-

PORT reports. Information gathered and reassessed during the review informed the development 

of the proposed amendments.  

Since the adoption of the 2024 amendments and as registered fund industry members 

further considered implementation, we have received additional information from industry 

members about the burdens of filing Form N-PORT reports within 30 days of month end through 

staff outreach to registered funds and fund administrators, as well as a letter from a group 

representing the registered fund industry.13 During staff outreach, industry members raised 

concerns about filing complete and accurate Form N-PORT reports within 30 days. Industry 

members discussed certain dependencies that could impact the ability to have Form N-PORT 

reports complete and error-free within this timeframe. For example, registered funds may rely on 

third parties for certain data related to liquidity, derivatives, or risk metrics, and in turn, those 

third parties may have their own data dependencies. In some cases, particularly for funds with 

complex strategies, the third parties may not provide data until shortly before the 30-day filing 

deadline. These delays result in limited time for internal reviews and signoffs on the data, 

particularly considering that some time is also needed to complete the filing process, and 

 
12  See 2024 Adopting Release, supra note 1, at section II.A.1. 
13  See ICI Letter. 



14 
 

increase the potential for errors in the report. Specifically, for fund complexes or fund 

administrators with a large volume of reports to file, it may take multiple days to handle the 

filing process.  

Due to the time required to receive, review, and file Form N-PORT information, industry 

members suggested that a 30-day filing deadline would increase the potential for errors and 

resubmissions and would cause some industry members to hire additional personnel to manage 

the condensed timeframe and the larger volume and greater frequency of filings. Industry 

members suggested that there would be a larger volume of filings as a result of the 2024 

amendments because they assumed that: (1) errors and resubmissions would increase; and (2) the 

Regulation S-X compliant presentation of holdings for the first and third fiscal quarter under Part 

F of Form N-PORT would be filed separately 60 days after quarter end. 

Industry members also discussed challenges in filing Form N-PORT reports within 30 

days of month end for closed-end funds that calculate their net asset values on a monthly basis 

and invest in private funds or other hard to value assets. Such closed-end funds have experienced 

growth in recent years and may continue to grow in number and size. Industry members 

suggested that, for some of these funds, there may not be an initial net asset value calculation 

until three weeks or later after month end. Industry members expressed concern that these funds 

may have to file reports that are not entirely accurate and then make an amended filing for 

accuracy.  

In light of concerns about the effects of a 30-day filing requirement, some registered fund 

industry members suggested that we further amend Form N-PORT to provide additional time, 



15 
 

such as 45 days, for funds to file monthly reports.14 In outreach, industry members suggested that 

a 45-day filing timeline, although still involving some costs, would reduce the risk of errors and 

reduce the need to hire additional personnel by providing additional time to gather, review, and 

file the required information. Some industry members suggested that a longer filing timeline, 

such as 60 days after month end or 60 days after quarter end, would further reduce burdens. 

In addition to the information obtained through outreach, we considered the concerns 

commenters raised in conjunction with the 2024 amendments.15 Commenters raised concerns 

that requiring monthly reporting within 30 days of month end would overburden registered 

funds, including fund internal systems and processes, as well as service providers. Commenters 

also discussed the overlap in teams that prepare, review, and file Form N-PORT reports with 

those that are involved with other required filings, suggesting that a 30-day filing timeline for 

Form N-PORT would cause strains on those teams. A few commenters further suggested that 

these strains would be pronounced for the months following the end of the reporting period when 

the annual and semiannual reports are due. Some commenters expressed concern about data 

security and the risk that confidential and proprietary registered fund information could be 

misappropriated as a result of unauthorized access. In general, these various concerns were 

consistent with the information we received through outreach. 

We also considered the Commission’s and staff’s use of Form N-PORT information and 

the potential effects of receiving Form N-PORT information later than 30 days after month end. 

As discussed in the 2024 Adopting Release, the quarterly filing requirement has limited the 

Commission’s ability to develop a timely and more complete understanding of the market. In 

 
14  See ICI Letter (stating that the Commission should extend the filing deadline to “at least 45 days” to avoid 

increased errors and resubmissions). 
15  See 2024 Adopting Release, supra note 1, at section II.A.1. 



16 
 

addition, although the Commission has had the ability to request registered fund records of Form 

N-PORT information within 30 days of month end, this has not been an effective substitute for 

receiving more timely information through filings.16 The Commission and its staff use Form N-

PORT information to, among other things, monitor industry trends, identify risks, inform policy 

and rulemaking, and assist Commission staff in examination and enforcement efforts. Timely 

Form N-PORT data improves the Commission’s ability to (1) conduct more targeted and timely 

monitoring efforts; (2) analyze risks and trends more accurately; and (3) better assess the breadth 

and magnitude of potential market events and stress affecting particular issuers, asset classes, 

counterparties, or market participants. The Commission’s ability to perform these functions 

effectively and efficiently benefits investors and the markets, including for example during times 

of market stresses and events.  

 As a general matter, the Commission adopted the 30-day filing requirement because (1) 

given that registered funds were already required to maintain records of Form N-PORT 

information within the 30-day period in which filings would be due, the Commission did not 

expect the burden to be significant;17 (2) the Commission historically has viewed access to Form 

N-PORT information within 30 days of month end as important to furthering our mission to 

protect investors;18 and (3) delays in receipt of Form N-PORT information reduce the utility of 

the information for the Commission.19 The additional information we have received from market 

participants following adoption of the 2024 amendments as funds further considered 

implementation suggests, however, that the burdens of filing Form N-PORT reports within 30 

 
16  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.57. 
17  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.75. 
18  See id. at paragraph accompanying n.60. 
19  See id. at paragraph accompanying n.61. 



17 
 

days of month end would be greater than the Commission anticipated due to the time it takes to 

compile, review, and file certain data, particularly for registered funds with complex strategies or 

certain types of closed-end funds, and the risk of errors and resubmissions if processes must be 

condensed. Providing an additional 15 days to file Form N-PORT reports should mitigate these 

burdens, but generally would not decrease the utility of the information for the Commission 

significantly or the indirect benefits to investors associated with the Commission’s use of Form 

N-PORT information. As a result, we are proposing to extend the filing timeframe to provide 

registered funds with 45 days after month end to file Form N-PORT reports.  

Providing 45 days for registered funds to file Form N-PORT reports would reduce 

burdens for the funds and their service providers, as they would have additional time to gather 

information, verify its accuracy, and prepare and make the filings. This additional time should 

also mitigate the effect that a monthly filing requirement would have on the workload of 

personnel or service providers that prepare and file Form N-PORT reports.20 Moreover, the 

additional time should reduce the potential for errors in Form N-PORT filings and reduce 

potential resubmissions. By reducing costs associated with the 2024 amendments, the proposal 

should also mitigate the extent to which costs associated with monthly reporting requirements 

are passed on to registered fund shareholders. We also recognize that the additional time to file 

would reduce the sensitivity of the information filed with the Commission, which should reduce 

the concern that some industry members have raised about data security and the risk that 

 
20  In 2016, when the Commission first adopted a requirement to file Form N-PORT reports within 30 days of 

month end, the Commission suggested that lag times of more than 30 days would make monthly reporting 
impractical, as reports would overlap with preparation time. See Investment Company Reporting 
Modernization, Investment Company Act Release No. 32314 (Oct. 13, 2016) [81 FR 81870 (Nov. 18, 
2016)] (“Reporting Modernization Adopting Release”), at nn.462-464 and accompanying text. Commenters 
on the 2024 rulemaking did not raise this overlap as a concern, although we understand that registered 
funds and their service providers would be the ones to bear this type of effect most directly. Given that the 
directly affected parties have not raised the overlap as a concern, we do not at this time view the overlap as 
a compelling reason to require reports to be filed within 30 days of month end.  



18 
 

confidential and proprietary registered fund information could be misappropriated as a result of 

unauthorized access.  

While these burden reductions would largely be relative to the 2024 amendments, which 

have not gone into effect, the proposed approach would also reduce burdens associated with the 

30-day recordkeeping requirement that registered funds historically have satisfied. Under the 

recordkeeping requirement, registered funds were required to gather and record Form N-PORT 

information within 30 days of month end. In contrast, the current proposal would not require 

registered funds to complete particular steps within 30 days of month end, rather a complete 

submission of monthly data would be due to the Commission within 45 days of month end. As a 

result, if adopted, the proposed approach would provide funds with more time to gather and 

review information than has historically been available or that would be available under the 2024 

amendments. This additional time would likely reduce burdens, particularly in cases where 

information is collected through a manual or otherwise time-consuming process, such as the 

example raised in outreach about delays in valuation information for certain closed-end funds. 

Moreover, relative to the requirement for registered funds to gather and record Form N-PORT 

information within 30 days of month end, a requirement to file the information with the 

Commission within 45 days of month end should reduce costs because funds that continue to 

gather the required information within 30 days of month end would then have 15 additional days 

just to prepare that information for filing with the Commission. 

 Given the additional information we have received about the challenges and burdens of 

filing Form N-PORT reports within 30 days of month end, as well as the increased risk of errors, 

we considered the effects of additional filing time on the utility of the reported information for 

the Commission and staff. As the Commission recognized in 2024, less timely data reduces the 



19 
 

utility of the information for the Commission. At the same time, data quality issues, such as 

errors in the reported information, can also affect the utility of the data. Overall, we anticipate 

that providing registered funds with 15 additional days to file monthly reports would not have a 

significant negative effect on the utility of the information, and the potential increase in data 

accuracy and reliability could provide benefits to the Commission.  

Specifically, providing an additional 15 days for filing monthly Form N-PORT reports 

would likely not have a significant effect on many of the Commission’s uses of the data, such as 

for monitoring and for risk and trend analysis, and the anticipated improvement in data quality 

would be a net benefit for these purposes. While the less timely data would in some cases reduce 

the utility of Form N-PORT information when market events occur, the monthly filing cadence 

would result in the Commission still having access to relatively recent data from registered 

funds’ most recently filed reports.21 Under the proposal, Form N-PORT information the 

Commission receives would be stale by about a month and a half, while the 2024 amendments 

would result in information that is stale by about a month, and the prior quarterly filing 

requirement resulted in information that is stale by up to five months. As a result, although 

providing registered funds with additional time to file Form N-PORT reports would reduce the 

utility of the information for the Commission, the effect of the additional 15 days to file Form N-

PORT on the utility of the information is generally small and justified by the reduced burden on 

these funds and the anticipated improvement in data quality.  

 
21  For example, if a market event occurred at the end of Dec., a 30-day filing timeline would result in the 

Commission receiving information for the month of Nov. around the time of the market event, while a 45-
day filing timeline would result in the Commission needing to use information for the month of Oct. In 
contrast, if a market event occurred in mid-Dec., the 30-day filing timeline and 45-day filing timeline 
would both result in the Commission needing to use information as of the month of Oct. to help assess the 
effects of the event. 



20 
 

We considered providing more time to file than we are proposing, such as 60 days after 

month end, or requiring monthly reports on a quarterly filing cadence (e.g., with reports for each 

month in a fiscal quarter due 45 or 60 days after quarter end). A longer filing timeframe would 

reduce the utility of the information for staff oversight and analysis, and the associated benefits 

of such activity for investors, because the reported information is increasingly less likely to 

reflect reasonably current portfolio holding-related information as the filing deadline moves 

further away from the end of the month to which the information relates. While we recognize 

that there may be certain efficiencies for registered funds and vendors associated with a quarterly 

filing cadence, as discussed in the 2024 Adopting Release, this approach results in the 

Commission receiving data that is multiple months old and, in past experience, has limited the 

Commission’s ability to develop a timely and more complete understanding of the market, 

thereby impeding its ability to respond to market stresses and events as they are developing. In 

addition, it is unclear that extending the filing timeframe beyond 45 days after month end would 

significantly reduce the risk of errors in reported information, as registered funds already have 

infrastructure for collecting the required information within 30 days after month end. 

Furthermore, in light of the other proposed amendments to the form, we anticipate a reduction in 

reporting burden for most registered funds, which could potentially reduce the need for 

additional time to file Form N-PORT reports. 

We request comment on the proposed changes to the timing and frequency with which 

registered funds would be required to file reports on Form N-PORT, including: 

1. As proposed, should we extend the deadline for filing reports on Form N-PORT 

from 30 days to 45 days after the end of the month? Should we instead retain the 

30-day filing deadline? Should we instead use a different deadline, such as 35 or21 
 

60 days after the end of the reporting month? How would a different deadline 

affect burdens for registered funds and data quality? 

2. To what extent would the additional 15 days to file Form N-PORT, relative to the 

2024 amendments, reduce burdens for registered funds? Would the additional 15 

days to file reduce costs associated with implementation compared to a 30-day 

filing deadline, and, if so, to what extent? Would the additional 15 days to file 

reduce the potential for errors in the reports compared to a 30-day filing deadline, 

and, if so, to what extent? Would the additional 15 days to file reduce strains on 

reporting teams that prepare, review, and file Form N-PORT reports and that are 

also involved with other required filings and reduce the need for registered fund 

advisers or administrators to hire additional personnel, and, if so, to what extent? 

3. Would a 45-day filing deadline affect registered funds that use vendors to prepare 

or file Form N-PORT reports differently than funds that do not use vendors, and, 

if so, in what ways? For funds that use vendors, would a 45-day filing deadline 

provide sufficient time for coordination between funds and vendors?  

4. Are there certain periods of a year where 45 days after month end would not 

provide sufficient time for filing Form N-PORT reports? For example, should we 

provide additional time beyond the proposed 45-day deadline to file Form N-

PORT reports for months that correspond to the end of the registered fund’s fiscal 

year or fiscal half-year, in order to provide more time during periods that funds 

are preparing annual and semiannual reports? If so, how much time (e.g., 60 

days)? How much additional burden would a 45-day deadline impose on 

registered funds during those times relative to other times of the year? Are there 



22 
 

other ways to reduce burden during those times? Should we provide more time to 

file Form N-PORT reports for months that relate to fiscal quarter ends more 

generally? Are there ways to limit the impact on the Commission’s use of Form 

N-PORT information if we were to provide additional time to file for particular 

months? 

5. Would a 45-day filing timeline create new or different burdens for registered 

funds and service providers, relative to a 30-day filing timeline, that we should 

consider? For example, would there be additional burdens associated with 

overlaps in report preparation time (i.e., with a 45-day deadline, the report for 

Month 1 is not due until approximately 15 days after the fund begins to prepare 

the report for Month 2)? 

6. What are the costs and benefits of a monthly filing frequency for smaller 

registered funds? For example, do smaller funds have a high administrative or 

operational cost in preparing these reports disproportionate to their other 

expenses? Would monthly filing of portfolio holdings significantly affect how and 

whether smaller funds can do business? 

7. Should certain types of registered funds, such as closed-end funds or smaller 

funds, have a different amount of time to file Form N-PORT reports or be 

permitted to file on a different frequency? If so, what types of funds should be 

subject to different requirements and what would those requirements be (e.g., 

filing within 30 or 60 days of month end, or filing within 30, 45, or 60 days of 

quarter end)? How would those certain types of funds benefit from different 

requirements? What types of different challenges do these funds face, and would 



23 
 

different requirements reduce those challenges, costs, and burdens? Are there 

ways to limit the impact on the Commission’s use of Form N-PORT information 

if we were to provide a different reporting timeline or frequency for certain 

registered funds? 

8. Is there any specific information that registered funds should have additional time 

to file, such as through an exhibit or attachment to the original filing or a separate 

filing type? If so, what information, and how much time do funds need to compile 

and verify that information? Is there specific information that registered funds 

could file with a high level of accuracy under the current timeline of 30 days after 

month end? Would it be challenging or burdensome for registered funds to file 

information at different intervals?  

9. Should we, as proposed, require registered funds to file reports on Form N-PORT 

on a monthly basis? Should we instead revert to requiring funds to file monthly 

reports on a quarterly basis like the previous requirements, or require funds to file 

reports on a different frequency altogether? If we require funds to file monthly 

reports on a quarterly basis, when should reports be due (e.g., 45 or 60 days after 

quarter end)? 

10. Are there other effects of providing an additional 15 days to file Form N-PORT, 

relative to the 2024 amendments, on registered funds, service providers, investors, 

the Commission, or others that we should take into account? 

11. Should we require registered funds to make records of Form N-PORT information 

within 30 days of month end, as was required prior to the 2024 amendments? 

What would be the effects of providing funds with 45 days to file Form N-PORT 



24 
 

reports without the historical requirement to make records of Form N-PORT 

information within 30 days of month end? Would this effectively result in funds 

having additional time to gather and verify the accuracy of information compared 

to the 30-day recordkeeping requirement? If so, are there certain types of 

information for which the additional time to gather and verify would be 

particularly helpful? Alternatively, would a 45-day filing deadline have limited, or 

no, effect on the timeline for gathering and verifying the accuracy of information 

because of the time needed for filing-related tasks or for other reasons? Are there 

benefits to a 30-day recordkeeping requirement that we should account for in our 

analysis? Would those benefits support adopting a 30-day recordkeeping 

requirement, or a requirement to maintain records within a different timeframe, as 

part of this rulemaking? 

12. Are there feasible alternatives to the proposed requirement to file monthly reports 

within 45 days of month end that would minimize reporting burdens on registered 

funds while maintaining the utility of the information reported to the 

Commission? Does the proposal appropriately balance the utility of the 

information to the Commission in relation to the costs to registered funds and 

their affiliated persons of providing the information?22 Does publication 

frequency or any other aspect of the proposal affect the analysis of these 

questions? 

 
22  See section 30(c)(2) of the Investment Company Act [15 U.S.C. 80a-29(c)(2)] (providing that, if the 

Commission requires information to be filed more frequently than annually under section 30 of the 
Investment Company Act, it shall consider and seek public comment on: (1) feasible alternatives that 
minimize reporting burdens, and (2) the utility of the information to the Commission in relation to 
associated costs). 



25 
 

B. Publication Frequency 

Upon further review of the publication frequency of Form N-PORT, we are proposing to 

require public disclosure of registered funds’ portfolio holdings for the third month of each fiscal 

quarter with a 60-day delay instead of requiring public disclosure of report information for every 

month with a 60-day delay after the end of the relevant month.23 This proposal mirrors the 

publication frequency of portfolio holdings that had been in place since 2004.24 As part of this 

review, we considered issues raised by commenters in connection with the 2024 amendments, 

statements of the petitioner in a challenge of certain of the 2024 amendments in the Fifth Circuit, 

and information provided by market participants following the adoption.25 

The review suggests that the potential effects of more frequent publication of a registered 

fund’s portfolio holdings could be more significant for some funds than the Commission 

previously appreciated.26 Those effects include additional costs that an increased publication 

frequency could impose on some registered funds, especially with the use of advancing 

technology, with a magnified effect on certain types of funds, such as those with actively 

managed strategies. While commenters raised these concerns in connection with the 2024 

amendments, they have also been raised in post-adoption communications.  

 
23  See 2024 Adopting Release, supra note 1, at section II.A.2. 
24  See, e.g., Reporting Modernization Adopting Release, supra note 20 (adopting new Form N-PORT to 

require certain registered investment companies to report information about their monthly portfolio 
holdings and rescinding Form N-Q); Shareholder Reports And Quarterly Portfolio Disclosure Release, 
supra note 2 (adopting Form N-Q and requiring quarterly portfolio holdings disclosure). 

25  See, e.g., 2024 Adopting Release, supra note 1, at section II.A.2; Registered Funds Association v. SEC, No. 
24-60550 (5th Cir. 2024); ICI Letter (suggesting that the Commission should revert to quarterly publication 
of Form N-PORT reports and extend the reporting timeframe to at least 45 days after month end). 

26  The discussion in this section of the release does not relate to ETFs that are required to disclose their 
portfolio holdings on a daily basis under 17 CFR 270.6c-11 (rule 6c-11), as changes to Form N-PORT do 
not affect the frequency at which these funds’ portfolio holdings are made public. See 17 CFR 270.6c-
11(c)(1)(i) and (c)(2).  



26 
 

Specifically, external parties may use information about a registered fund’s portfolio 

holdings to trade in a way that harms the fund.27 While this risk exists with any information 

about a fund’s portfolio holdings, more frequent publication of portfolio holdings may increase 

the risk. External parties may obtain at no cost the benefits of the investment research and 

analysis that went into developing the fund’s investment strategies. For example, external parties 

may exploit a fund’s portfolio holdings information to reverse engineer and copy the strategy, 

often called “free riding.” External parties may also “front run” a fund by using a fund’s 

portfolio holdings information to identify positions that the fund may be acquiring or disposing 

of and trade ahead of the fund. In combination with fund flow information, external parties may 

use portfolio holdings information to front run the sales of funds that experience large outflows 

and purchases of funds with large inflows. These activities may lead to more (or less) demand 

for an investment, which could drive up the price of trading, inhibit the investment adviser’s 

ability to achieve the fund’s investment strategies, and harm fund performance. These risks may 

affect registered funds differently depending on various factors, such as the quality and age of 

the data and characteristics of the fund (e.g., its investment strategy and amount of portfolio 

turnover). 

Registered funds and, indirectly, their shareholders pay investment advisers management 

fees to perform important research and analytical functions, construct funds’ investment 

strategies, and manage funds’ portfolios. Free riding and front running are ways that external 

parties may take advantage of that work without compensating investment advisers. As a result, 

 
27  Commenters and other parties have at times referred to these activities as “predatory trading.” 



27 
 

investment advisers may be less willing to devote resources to research and analysis, which may 

reduce their effectiveness and information production, potentially reducing price efficiency.28 

These risks increase for many actively managed registered funds as technology, such as 

artificial intelligence, evolves, becomes cheaper, and usage increases. For example, an external 

party may use technology tools to aggregate large amounts of data to predict not-yet-completed 

or future portfolio management decisions to free ride on the investment adviser’s work or front 

run the fund.29 Artificial intelligence continues to evolve rapidly and is just one example of 

rapidly advancing developments that may increase the risk of external parties using information 

about a registered fund’s portfolio holdings to trade in a way that harms the fund. The proposed 

amendments would require four publications of portfolio holdings per year, instead of the 

monthly publication frequency required by the 2024 amendments that would result in 12 

publications per year. Along with advances in technology, the 2024 amendments’ quadrupling of 

the amount of available data also could increase the risk that a fund’s proprietary investment 

strategy or trading inventions are inferred by external parties.  

Registered funds vary in how often they voluntarily publish their portfolio holdings 

depending on their sensitivity to transparency and their investment objectives and strategies.30 

While some registered funds frequently release complete portfolio holdings information on their 

websites and to data aggregators, others make more limited portfolio holdings public, such as a 

list of 10 largest holdings, and still others do not provide any voluntary portfolio holdings 

 
28  See infra sections III.D.1 and III.D.3. 
29  See ICI Letter (noting the risks of evolving technologies and artificial intelligence to allow predatory 

traders to accurately analyze and anticipate a registered fund’s next investment transaction or mimic its 
investment strategy, which may affect almost every type of actively managed fund). 

30  See 2024 Adopting Release, supra note 1, at n.230 (discussing a paper estimating that, at year-end 2019, 
approximately 56% of U.S. equity mutual funds’ portfolio disclosures were voluntary monthly disclosures).  



28 
 

information at all. Registered funds may choose to disclose only the required portfolio holdings 

information because additional data may reveal confidences about their investment strategies and 

increase the risk of free riding or front running. For example, certain actively managed, fixed 

income, less liquid, or concentrated investment strategies may require some time to build or 

dispose of portfolio holdings or to find buyers or sellers at the desired target price. This increases 

the risks of other parties trading ahead of the fund before the fund has finished building or 

disposing of a position.  

Under the 2024 amendments, information reported for each month will be made public 

60 days after month end. This delay will mitigate some of the risks of more frequent disclosure 

of registered funds’ portfolio holdings, such as the risks of front running, because a fund will be 

able to build or dispose of a position before a report is made public. However, certain investment 

strategies (such as those that are concentrated and with significant positions) may, at times, need 

more than 60 days to build or dispose of a position. In addition, the 60-day delay may not 

effectively address the risk that publishing a registered fund’s portfolio 12 times a year will 

contribute to free riding, particularly as technology continues to advance.  

We recognize there are benefits of publishing a registered fund’s portfolio holdings on 

Form N-PORT more frequently than the quarterly publication requirement. The Commission 

considered these benefits in the 2024 amendments.31 For example, such transparency allows 

investors to review and monitor information about registered fund portfolio holdings on an 

ongoing basis and may help better inform their investment decisions. It also allows other market 

participants, such as data aggregators and investment advisers, to better advise investors and help 

manage their investment portfolios. More frequent publication of portfolio holdings information 

 
31  See 2024 Adopting Release, supra note 1, at n.103 and accompanying text.  



29 
 

also helps reduce the imbalance of information between different types of investors and market 

participants, some of whom may have access to portfolio holdings information before a quarterly 

Form N-PORT publication.32 While these are some ways that additional transparency could 

benefit investors, the Commission received limited feedback in connection with the 2024 

amendments about whether investors or others would use additional Form N-PORT information 

in these ways.33  

We have considered available information, including the costs and benefits of publication 

frequency of portfolio holdings, and are proposing to require public disclosure of registered 

funds’ portfolio holdings only for the third month of each fiscal quarter with a 60-day delay.34 

This would maintain the quarterly publication frequency of portfolio holdings disclosure that had 

been in place for more than twenty years prior to the 2024 amendments and means that a 

registered fund would have up to five months to build or shrink its positions before its portfolio 

holdings are made public.35 A quarterly frequency would reduce costs, including risks that an 

external party can infer a fund’s proprietary investment strategy or trading intentions, as 

 
32  Exhibits required under Part F of Form N-PORT present portfolio holding information in a Regulation S-X 

compliant format that is consistent with how registered funds have historically presented this information in 
annual and semi-annual reports. Under the proposal, registered funds would continue to file this 
information for their first and third fiscal quarters, no later than 60 days after the end of the quarter. If the 
proposed requirement for registered funds to file monthly reports within 45 days of month end is adopted, 
we anticipate providing a separate submission type on EDGAR for funds to file Part F exhibits within 60 
days of the end of a fund’s first and third fiscal quarters. This would result in separate submission types for 
the monthly reports due within 45 days of month end and the Part F exhibits due within 60 days of first and 
third-quarter end. Historically, registered funds have filed Part F exhibits in connection with publicly 
available Form N-PORT filings because, prior to the 2024 amendments, Part F exhibits were due at the 
same time as those Form N-PORT filings. 

33  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.85 (discussing comment letters 
that supported publishing Form N-PORT reports more frequently than quarterly). 

34  Certain of the reported information, such as information about liquidity, use of derivatives, and 
miscellaneous securities, would remain confidential for all months of a quarter. See General Instruction F 
of Form N-PORT. This aspect of the form is unchanged in this proposal. 

35  For example, if a registered fund’s fiscal quarter ends on Mar. 31, an investment made on Jan. 1 would not 
need to be disclosed until May 30, or 60 days after Mar. 31. 



30 
 

compared to monthly public reporting. Importantly, as public information of portfolio holdings 

has generally increased, these proposed amendments are not intended to inhibit registered funds 

from publishing their portfolio holdings more frequently than quarterly on their websites or 

through data aggregators. The proposal takes into account our review and rebalancing of the 

benefits of information available for investors with the potential harms caused by more frequent 

publication of portfolio holdings, such as free riding or front running.36  

We request comment on the proposed amendments to the publication frequency of 

portfolio holdings on Form N-PORT, including:  

13. How often should portfolio holding information be disclosed publicly? Should 

we, as proposed, require registered funds to publish their portfolio holdings 

quarterly? Should the publication frequency be shortened or lengthened, for 

example, to monthly or semi-annually? What are the costs and benefits of each 

publication frequency? Do retail investors find publication of this information 

helpful and/or useful? If publication of this information is used primarily by 

institutional investors and data aggregators, should we require this information to 

be continued to be made public? 

14. What would be the costs and consequences of quarterly publication of portfolio 

holdings, based on experience with the historic quarterly frequency? Please 

provide concrete examples and data. For example, does the historic quarterly 

publication frequency lead to free riding, front running, or other actions by 

 
36  Section 45(a) of the Act requires information in reports filed with the Commission pursuant to the Act to be 

made public unless we find that public disclosure is neither necessary nor appropriate in the public interest 
or for the protection of investors. For the reasons discussed above, we would view that keeping the data for 
the first and second months of a registered fund’s fiscal quarter confidential, and the data for the third 
quarter confidential until the expiration of the 60-day period provided by the proposal, as necessary or 
appropriate in the public interest or for the protection of investors. 



31 
 

external parties that harm registered funds, and, if so, how, to what extent, and for 

which kinds of funds? Would these actions by external parties affect fund 

performance, and, if so, how? Would these actions reduce research and resources 

spent on research, and, if so, by how much?  

15. What would be the costs and consequences of more frequent than quarterly 

publication of portfolio holdings? Please provide concrete examples and data. For 

example, would more frequent publication increase free riding, front running, or 

other actions by external parties that harm registered funds, and, if so, how? 

Would these actions by external parties affect fund performance, and, if so, how, 

to what extent, and for which kinds of funds? Would these actions reduce research 

and resources spent on research, and if so, by how much? Are there 

administrative, operational, or other costs of more frequent publication of 

portfolio holdings. And if so, what are they? Would some registered funds change 

their investment strategies and other business practices, and, if so, what would the 

changes be? How many, and what kinds of, funds would be affected, and what 

would the effects be? Please provide concrete examples and data. 

16. What are the benefits of more frequent publication of portfolio holdings than a 

quarterly frequency? Please provide concrete examples and data. For example, 

how do investors, other market participants, such as data aggregators and 

financial intermediaries, and the broader market use or plan to use portfolio 

holdings information? How do they use portfolio holdings information to inform 

their investment decisions or perform other tasks? How does standardized 

information in a central location, as opposed to individual websites, benefit 



32 
 

investors and other market participants? Do registered funds voluntarily publish 

data about their portfolios to compete for investors? How does the publication of 

portfolio holdings information improve market efficiency? 

17. Should we publish monthly portfolio holding information on Form N-PORT, but 

with a longer delay than provided in the 2024 amendments? For example, should 

monthly reports be made public 90 days after the end of the reporting period? 

Should monthly reports for each month in a fiscal quarter be made public at the 

same time, such as 60 or 90 days after the end of the fiscal quarter? Would 

delaying publication of monthly reports reduce the risks of free riding, front 

running, or similar actions relative to the 2024 amendments? Would this type of 

delayed dissemination of monthly information benefit investors?  

18. How have market participants used technology, including artificial intelligence, in 

connection with portfolio holdings information? Is the information used in ways 

that increase free riding, front running, or similar actions and adversely affect 

registered funds and their shareholders? If so, who has used the information, and 

in what ways, and how has this use affected funds and shareholders? Please 

provide concrete examples of which kinds of funds have been affected and what 

the effects have been, and any related data. Is this usage expected to increase or 

change in the future, and if so, in what ways, and how much? How would more or 

less frequent disclosure of registered funds’ portfolio holdings information affect 

these uses? Conversely, is the information used in ways that improve investor 

choice, information, and experience or otherwise benefit investors? 



33 
 

19. What types of registered funds are more adversely affected by more frequent 

publication of portfolio holdings? How are they affected? Should certain funds, 

for example, smaller or actively managed funds, or closed-end funds or non-

diversified funds, be exempt or have different treatment in publication of portfolio 

holdings? What type of exemption or changes would suffice, for example, longer 

confidential treatment? If so, for what longer period should information remain 

confidential? Would investors and market participants suffer harm from or 

disadvantages from a longer period, and if so, how? For registered funds that are 

less likely to be adversely affected, should the Commission retain the monthly 

publication timing adopted in 2024?  

20. Should publication be required on calendar quarter-end instead of fiscal quarter-

end? What are the costs and benefits of moving to a calendar quarter-based 

publication frequency? For registered funds with fiscal year ends that do not 

match a calendar quarter, how could requirements for the publication of portfolio 

holdings be changed to minimize additional publications as the result of annual 

and semi-annual shareholder reports?  

21. How long should the period for publication delay be? Should the delay be 

shortened or lengthened, for example, to 45, 75, or 90 days? What are the costs 

and benefits of a 60-day or other period of delay? Please provide concrete 

examples and data. For example, how does the current 60-day delay affect the 

risks of free riding, front running, or similar actions? How would a shortened or 

lengthened timeframe affect these risks? What other effects would a different 

timeframe have on fund performance? 



34 
 

22. Are there other amendments to Form N-PORT that would reduce compliance 

burdens and the risks of disclosing portfolio holdings? For example, should the 

percentage of assets allowed to be reported non-publicly on Form N-PORT as 

miscellaneous securities (Part D) be lower or higher than the current 5% limit, for 

example, 3%, 8%, or 10%? What would the costs and benefits be of amending 

this or any other reporting requirement? 

23. Do investors or others use the presentation of portfolio holdings that registered 

funds provide under Part F of Form N-PORT for their first and third fiscal 

quarters? Are there ways we could make the Part F information more user-

friendly or less costly for funds to prepare?37 For example, are there other ways to 

disclose the portfolio information in Part F that would facilitate the use of 

artificial intelligence or other tools to analyze the portfolio holdings information, 

and if so, how? As another example, should we require only certain holdings but 

not the complete portfolio holdings, and, if so, which holdings? For instance, 

should we require presentation of a certain number of the largest issues (e.g., 10, 

25, or 50) and any other issues that exceed a particular percentage of the 

registered fund’s net asset value (e.g., 1% or 5%)? Should we require each 

registered fund to provide a graphical representation of holdings for reports 

covering the end of the first and third quarters of the fund’s fiscal year, similar to 

the graphical representations of holdings provided in funds’ annual and 

 
37  See 2024 Adopting Release, supra note 1, at section II.A.3 (discussing comments on the burdens of 

providing a Regulation S-X compliant presentation of portfolio holdings more frequently than Form N-
PORT requires). 



35 
 

semiannual shareholder reports?38 Is there other information that would be helpful 

to investors in a more user-friendly presentation for these quarter ends, such as a 

registered fund’s net assets, total number of portfolio holdings, or other fund 

statistics?39 Are there other tools that would be helpful to investors in 

understanding and analyzing a fund’s portfolio holdings, for example, artificial 

intelligence tools on registered funds’ websites, that would decrease the need for 

Part F? If so, what kinds of tools would serve this purpose, and which information 

could be removed from Part F? If the information that registered funds currently 

provide under Part F is not typically useful to investors or others, should we 

remove Part F from Form N-PORT? Certain Commission rules reflect that, due to 

Part F requirements, registered funds prepare schedules of their complete 

portfolio holdings for the close of their first and third fiscal quarters in a 

Regulation S-X compliant format.40 If we amend or remove Part F of Form N-

PORT, should we likewise amend or remove associated requirements from these 

other rules?  

 
38  See, e.g., Item 27A(f) of Form N-1A (requiring a graphical representation of holdings in annual and 

semiannual shareholder reports of funds that register on Form N-1A). 
39  See, e.g., Item 27A(e) of Form N-1A (requiring funds that register on Form N-1A to provide certain fund 

statistics in their annual and semiannual shareholder reports, and allowing these funds to provide additional 
statistics that the fund believes would help shareholders better understand the fund’s activities and 
operations, such as tracking error, maturity, duration, average credit quality, or yield). 

40  See, e.g., 17 CFR 270.30e-1(b)(2)(ii) (requiring, among other things, that an open-end fund registered on 
Form N-1A (other than a money market fund) make available on its website the fund’s complete portfolio 
holdings as of the close of the most recent first and third fiscal quarters, presented in accordance with 
Regulation S-X); 17 CFR 270.30e-3(b)(1)(iv) (permitting a management company registered on Forms N-2 
or N-3 to send a notice of website availability of a fund’s shareholder reports to satisfy shareholder report 
transmittal requirements if certain conditions are met, including website availability of the fund’s complete 
portfolio holdings as of the close of the most recent first and third fiscal quarters, presented in accordance 
with Regulation S-X). 



36 
 

C. Other Proposed Amendments to Form N-PORT 

In addition to the proposed amendments to provide registered funds with fifteen 

additional days to file monthly reports and to revert to the quarterly publication frequency, we 

are proposing amendments to Form N-PORT to refine the information funds provide while 

maintaining the usability and reliability of Form N-PORT data. Specifically, we are proposing to 

modify certain information collected on portfolio level risk metrics and returns to narrow their 

scope, and proposing to eliminate certain information collected on registered funds’ compliance 

with names-related regulatory requirements, payoff profiles of non-derivatives instruments, 

convertible bonds, and the reason a single holding has multiple liquidity classifications. We are 

also proposing to modify how funds with ETF share classes report net assets and shareholder 

flows to require separate information for ETF share classes. Additionally, we are proposing to 

require registered funds to provide certain additional identifying information, such as ticker 

symbols and certain class-level information, as applicable. The key aspects of the proposed 

amendments are described in Table 2 below and discussed in more detail throughout this section. 

Table 2. Comparison of Current and Proposed Requirements 

 Current Requirement Proposed Requirement 
Portfolio Level Risk Metrics 
Scope of registered funds that 
must report  

The average value of the 
fund’s debt securities 
positions for the previous 3 
months, in the aggregate, 
exceeds 25% of the fund’s net 
asset value 

The average value of the 
fund’s debt securities 
positions for the previous 3 
months, in the aggregate, 
exceeds 50% of the fund’s net 
asset value 

Interest rate risk metrics Report both DV01 and 
DV100 
 
Report DV100 separately for 
each currency for which the 
fund had a value of 1% or 
more of the fund’s net value 

Report DV100 only 
 
 
Report DV100 aggregated 
across all currencies for 
which the fund had a value of 
1% or more of the fund’s net 
asset value 



37 
 

 Current Requirement Proposed Requirement 
Credit spread risk metrics Report separately for 

investment grade and non-
investment grade exposures 

Aggregate investment grade 
and non-investment grade 
exposures 

Return Information 
Reporting by multiple class 
funds 

Report separately for each 
class 

Report for a single 
representative class 

Calculating returns Calculate in accordance with 
methodologies outlined in 
applicable registration form 

Calculate in accordance with 
methodologies outlined in 
applicable registration form, 
except do not deduct sales 
loads and redemption fees 

Reporting net realized gain 
(loss) and net change in 
unrealized appreciation 
(depreciation) attributable to 
derivatives 

Report separately by asset 
category and, within each 
asset category, further report 
by type of derivative 
instrument 

Report separately by asset 
category only 

Period of return information 
covered in each report (same 
change also made for flow 
information) 

One month Each of the preceding three 
months, in light of the 
proposed quarterly 
publication frequency 

Items for Elimination 
Names rule information (1) Definitions of the terms 

used in a registered fund’s 
name;  

(2) The value of the fund’s 
80% basket, as a 
percentage of the value of 
the fund’s assets;1 and  

(3) Whether each investment 
in the fund’s portfolio is 
in the fund’s 80% basket 

None 

Payoff profile for non-
derivatives 

Indicate payoff profile among 
the following categories 
(long, short, N/A) 

None 

Convertible securities 
information 

Report conversion ratio and 
delta (if applicable) 

None 

Multiple liquidity 
classifications 

If attributing multiple 
liquidity classifications to a 
single holding, indicate which 
of three possible 
circumstances is applicable 

None 

ETF Share Class Reporting 
Separate information reported 
for ETF share classes 

None Report net assets and flow 
information separately for the 



38 
 

 Current Requirement Proposed Requirement 
ETF share class, as well as 
the class’s ticker 

Identifying Information 
Provide ticker and certain 
class-level information, as 
applicable 

Registered funds report class 
identification numbers in 
connection with reporting 
class-level returns2 

Report ticker symbol by 
registrant, and for each class 
of a registrant or series, as 
applicable, as well as class 
names and class identification 
numbers. 

Notes: 
 
1. The names rule requires certain funds to adopt a policy to invest at least 80% of the value of their assets in 
accordance with the investment focus that a fund’s name suggests. In 2023, the Commission adopted 
amendments to broaden the scope of this requirement and to define “80% basket” generally as investments that 
are invested in accordance with the investment focus that a fund’s name suggests (“names rule amendments”). 
See rule 35d-1(g) under the Act. 
 
2. The proposed amendments would change this reporting and only require returns for a single representative 
class on Form N-PORT. 
 

 
 

Portfolio Level Risk Metrics 

Registered funds that invest certain amounts of their portfolios in debt instruments, or 

derivatives that provide exposure to debt instruments, currently are required to report specific 

portfolio level risk metrics on Form N-PORT.41 The reported risk metrics are intended to provide 

the Commission staff, investors, and other potential users with measures that can help them 

analyze how portfolio values might change in response to changes in interest rates or credit 

spreads.42 We are proposing to raise the threshold for determining which registered funds are 

required to report portfolio level risk metrics and to streamline the metrics they are required to 

report.43 Based on our experience using Form N-PORT data, as discussed below, the proposed 

 
41  See Item B.3 of current Form N-PORT. 
42  See Reporting Modernization Adopting Release, supra note 20, at section II.A.2.c. 
43  See Item B.3 of proposed Form N-PORT. 



39 
 

changes would not significantly affect the utility of the reported information about portfolio level 

risk metrics but would reduce burdens for funds.  

Registered funds are currently required to provide portfolio level risk metrics if the 

average value of the fund’s debt securities positions for the previous three months, in the 

aggregate, exceeds 25% of the fund’s net asset value. We are proposing to increase this reporting 

threshold from 25% to 50%. Registered funds that fall below the proposed threshold would no 

longer be required to provide information on portfolio level risk metrics. The proposed change to 

the threshold is designed to focus the risk metrics reporting requirement on funds with more 

significant exposure to debt securities to better balance the benefits and costs of the reporting. 

Registered funds that invest more than 50% of their net assets in debt securities, averaged over a 

three-month period, are more significantly exposed to changes in interest rates or credit spreads 

and associated changes in the funds’ portfolio values, in comparison to registered funds that 

invest at the 25% threshold. Setting the threshold at the higher 50% level would provide 

Commission staff, investors, and other potential users with more focused measures to help them 

analyze how portfolio values might change in response to changes in interest rates or credit 

spreads for registered funds that invest significantly in debt instruments, or in derivatives that 

provide exposure to debt instruments. 

We also propose to eliminate one risk metric and simplify the reporting of the other 

required risk metrics. Currently, registered funds are required to report two interest rate risk 

metrics, DV01 and DV100. DV01 reflects the change in value of a fund’s portfolio resulting 

from a 1 basis point change in interest rates, while DV100 reflects the change in value from a 

100 basis point change in interest rates. The Commission previously determined to require 



40 
 

registered funds to report both measures because, combined, they show how a fund’s exposure 

changes with different changes in interest rates and thus provide information about convexity.44  

Based on staff experience using Form N-PORT information, and given that our receipt of 

Form N-PORT information is delayed, we propose to eliminate the DV01 metric, which is 

typically used as a daily risk measure. Registered funds currently are required to report this 

metric for each currency for which the fund had a value of 1% or more of its net assets and report 

the metric across multiple maturities. In our experience, the DV100 metric that registered funds 

report has been more useful in monitoring funds’ exposures to interest rate risk over time. 

DV100 is among the most common measures of interest rate sensitivity, allows the staff to 

capture larger changes to interest rates (and corresponding “shocks” to the markets), and 

provides useful information about non-parallel shifts in the yield curve as compared to smaller 

measures like DV01. In addition, DV100 on its own provides some information about convexity 

because it measures larger changes in interest rates, and it can be combined with other 

information that registered funds report (such as the prevalence of holdings in certain instrument 

types, like zero coupon bonds and mortgage-backed securities) to monitor convexity.  

We also propose to simplify the reporting of the DV100 metric by requiring registered 

funds to report the aggregate change in the value of the portfolio from a 100 basis point change 

in interest rates across all applicable currencies (i.e., those that are 1% or more of the fund’s net 

asset value), rather than providing separate changes in value for each of those currencies. The 

Commission required DV100 for each applicable currency to help understand interest risk for 

 
44  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.155. The 

Commission also discussed that some filers may not calculate convexity internally, so requiring the two 
interest rate metrics was designed to mitigate the increase in reporting costs that would be associated with 
requiring registered funds to separately report a measurement of convexity.41 
 

registered funds with significant currency risk.45 Based on our experience, we can use other 

information reported on the form, such as the currency denomination of each portfolio holding, 

to help assess significant currency risk in conjunction with the aggregate DV100 information that 

funds would report under the proposal.46   

In addition, we propose to streamline the information reported on credit spread risk by no 

longer requiring registered funds to report credit spread risk metrics separately for investment 

grade and non-investment grade exposures. The Commission required separate reporting for 

investment grade and non-investment grade debt because credit spreads for investment grade and 

non-investment grade debt do not always shift in parallel or lock step, particularly in times of 

stress.47 Based on our experience, we can use information we separately receive on Form N-

PORT about debt securities’ coupons as a proxy for a registered fund’s relative exposures to 

investment grade and non-investment grade debt, as these different categories of debt generally 

have different coupon levels to account for their differing levels of risk. This information, 

combined with aggregated credit spread metrics under the proposal, would continue to provide 

information about credit spreads, and the risk associated with credit spreads.  

We are also proposing to require information about portfolio risk metrics to be reported 

in U.S. dollars for consistency in reporting. Consistent reporting, in turn, makes the information 

more useable and facilitates comparisons across registered funds. The proposed instruction is 

consistent with many registered funds’ current practices and aligns with how funds report 

changes in the value of the portfolio elsewhere in the form. Additionally, we understand that the 

 
45  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.148. 
46  See Item C.2 of current Form N-PORT (requiring registered funds to report the currency in which each 

investment is denominated). 
47  See Reporting Modernization Adopting Release, supra note 20, at text accompanying n.159. 



42 
 

proposed instruction is consistent with a common interpretation of DV100, with “DV” being an 

abbreviation for “dollar value.” When a registered fund reports portfolio level risk metrics in 

currencies other than U.S. dollars—particularly when the exchange rate between a given 

currency and U.S. dollars is significantly different from an exchange rate of 1.00—the fund’s 

risk metric values are more likely to be outside the range of typical risk metric values reported in 

U.S. dollars by similar funds, which has the potential to cause investor confusion and has 

negatively affected staff use of the reported information.   

The proposed amendments to risk metric reporting would, to a certain degree, reduce 

information for understanding and monitoring registered funds’ exposures to changes in interest 

rates and credit spreads across the yield curve. In particular, there would be less information 

about these exposures for registered funds with marginal or temporary exposure to debt 

securities, and somewhat less granular risk metric information for funds with more significant 

exposures to debt securities. However, the proposed changes would not significantly affect how 

the Commission uses Form N-PORT data, and the public would continue to have access to 

information about registered funds’ significant interest rate and credit spread risks from the form. 

On balance, the proposed amendments to portfolio level risk metrics would simplify registered 

fund reporting and reduce burdens while maintaining useability and reliability of Form N-PORT 

data. 

Return Information 

Currently, registered funds are required to report monthly total returns and, if the fund 

has multiple classes, to report returns for each class.48 For purposes of Form N-PORT, registered 

funds calculate returns using the same standardized formulas required for fund prospectuses and 

 
48  See Item B.5 of current Form N-PORT. 



43 
 

sales materials. The return information reported on Form N-PORT is intended to facilitate 

comparisons across registered funds and to help identify performance that appears inconsistent 

with a fund’s strategy or other benchmarks as a basis for further inquiry and monitoring.49  

We are proposing to simplify reporting by multiple class funds and to provide more 

specific instructions for calculating returns.50 We are also proposing to streamline information 

registered funds currently must report about gains (losses) or appreciation (depreciation) 

attributable to derivatives. Finally, in connection with revisiting the 2024 amendments and 

proposing to return to a quarterly publication frequency, we are proposing to require registered 

funds to report return and flow information for the three preceding months in a single report as 

was the requirement before the 2024 amendments to provide investors access to monthly data for 

a given quarter. (This requirement was removed as a part of the 2024 amendments because the 

amendments to the publication frequency gave investors access to monthly Form N-PORT 

reports.) 

Currently, multiple class funds are required to report monthly total returns and related 

identifying information for each class of the fund. We propose to require that multiple class 

funds report information for a single representative class rather than return information for each 

class within a fund. Under the proposal, the representative class would be selected in the same 

manner that Form N-1A registrants use to determine which class’s annual total returns to 

disclose in fund prospectuses. Using this approach, a registered fund can select which class to 

use as its representative class (e.g., the oldest class, the class with the greatest net assets), except 

the fund must: (1) select the class with 10 or more years of annual returns if other classes have 

 
49  See Reporting Modernization Adopting Release, supra note 20, at section II.A.2.e. 
50  See Item B.5 of proposed Form N-PORT. 



44 
 

fewer than 10 years of annual returns; and (2) select the class with the longest period of annual 

returns when the classes all have fewer than 10 years of returns.51 Based on our experience with 

the data, having return information for a single representative class of a multiple class fund 

should be sufficient for purposes of comparing registered funds and identifying performance that 

appears inconsistent with a fund strategy or other benchmarks, as returns across classes of a 

multiple class fund are generally consistent except for the effects of certain class-specific fees 

and expenses, and as discussed below, we are specifying that certain of these differences should 

not be accounted for in monthly returns reported on Form N-PORT. Moreover, certain 

performance information for all classes would remain available in fund prospectuses for an 

investor making an investment decision about the appropriate class in which to invest.  

We are also proposing to specify that registered funds should not deduct sales loads and 

redemption fees charged to shareholder accounts when calculating monthly returns.52 This 

approach is consistent with many funds’ current practices and consistent with prior staff 

guidance.53 Currently, total returns are to be reported in accordance with the methodologies 

outlined in applicable registration forms. The methodologies in Forms N-1A and N-3 require that 

sales loads and redemption fees charged to all shareholder accounts be deducted when 

calculating returns. The performance disclosures that Forms N-1A and N-3 require show the 

effects of these loads and fees for non-cumulative periods of one, five, and ten-years, while the 

information Form N-PORT provides is monthly. Deducting sales loads and redemption fees for 

each month over an indefinite number of reports could give investors the impression that these 

 
51  See Instruction 3(a) to Item 4(b)(2) of Form N-1A. 
52  See Item B.5 of proposed Form N-PORT. 
53  See Investment Company Reporting Modernization Frequently Asked Questions (Apr. 21, 2021) available 

at https://www.sec.gov/about/divisions-offices/division-investment-management/accounting-disclosure-
information/investment-company-reporting-modernization-frequently-asked-questions. 



45 
 

are ongoing fees and overstate their effect on performance. As a result, we are proposing to 

require that registered funds not deduct sales loads and redemption fees from the returns reported 

on Form N-PORT to provide for consistency across registered fund reporting and to avoid 

overstating the effects of sales loads and redemption fees in monthly return information reported 

on the form. 

In addition to monthly total returns, registered funds are currently required to report the 

net realized gain (loss) and net change in unrealized appreciation (depreciation) attributable to 

derivatives by asset category (e.g., commodity contracts, credit contracts, equity contracts), and 

within those asset categories, funds are required to report the same information for different 

types of derivative instruments (e.g., forward, future, option, swap). This derivative-related 

reporting is intended to help Commission staff, investors, and other potential users better 

understand how a registered fund is using derivatives to accomplish its investment strategy and 

the impact of derivatives on fund returns.54 We propose to eliminate the requirement that 

registered funds report the information by type of derivative instrument. As a result, registered 

funds would not need to separately report return information for each instrument type (e.g., 

equity options and equity swaps), and instead would report information only by asset class (e.g., 

equity contracts). Removing the need to separately report gain (loss) and appreciation 

(depreciation) information for each type of derivative instrument within a given asset category 

would reduce reporting burdens without significantly affecting the utility of the reported 

information, as the Commission and the public would continue to have derivatives-related 

information elsewhere on the form, such as the types and amounts of derivatives instruments the 

registered fund holds, to understand the impact of derivatives on fund returns. 

 
54  See Reporting Modernization Adopting Release, supra note 20, at section II.A.2.e. 



46 
 

Finally, because we are proposing to require that Form N-PORT reports be made public 

only for the third month in a fund’s fiscal quarter, rather than monthly, we likewise are proposing 

to require registered funds to report return information for each of the preceding three months in 

each report to avoid unintended effects on investor’s access to monthly return information, 

similar to how registered funds reported prior to the 2024 amendments. Prior to the 2024 

amendments, registered funds were required to report return information for each of the 

preceding three months in each report to provide investors access to monthly data for a given 

quarter since investors only had access to Form N-PORT reports for the third month of each 

quarter. In connection with requiring publication of monthly Form N-PORT reports in the 2024 

amendments, the Commission modified the form to require return information in each report 

only for the month that the Form N-PORT report covers because the amendments provided 

investors access to each monthly report. Our proposed approach would continue to provide 

investors with “batched” access to monthly return data for a given quarter, consistent with the 

Commission’s historical approach of requiring that investors have access to monthly return 

information on Form N-PORT regardless of the publication frequency. For the same reason, we 

are also proposing to require registered funds to report flow information for each of the 

preceding three months in a single Form N-PORT report.55 

Eliminating Reporting Items  

In addition to proposing to streamline the reporting of some information, we propose to 

remove certain required information from the form. Specifically, we are proposing to remove 

requirements to report information related to the registered fund’s compliance with the names 

rule, the payoff profiles of non-derivatives, certain information about convertible debt securities, 

 
55  See Item B.6 of current Form N-PORT; Item B.6 of proposed Form N-PORT. 



47 
 

and explanations of why a single investment has multiple liquidity classifications. Removing 

these requirements would not have a significant effect on the Commission’s uses of the data and 

are not expected to significantly affect the public’s ability to assess relevant information about 

the fund. 

The names rule amendments, among other things, broadened the scope of the requirement 

for certain funds to adopt a policy to invest at least 80% of the value of their assets in accordance 

with the investment focus that the fund’s name suggests (an “80% investment policy) and added 

reporting requirements on Form N-PORT related to a registered fund’s compliance with that 

rule.56 For a registered fund that is required to adopt an 80% investment policy under the names 

rule, the names rule amendments require the fund to report quarterly on Form N-PORT: (1) 

definitions of terms used in the fund’s name; (2) the value of the fund’s 80% basket, as a 

percentage of the value of the fund’s assets; and (3) whether each investment in the fund’s 

portfolio is in the fund’s 80% basket.57 We are proposing to eliminate these names rule-related 

reporting requirements on Form N-PORT.58  

The purpose of the names rule-related reporting requirements is to provide market-wide 

insight with respect to those registered funds that are subject to the 80% investment policy 

requirement for the Commission, its staff, and market participants. When these requirements 

were adopted, the Commission stated that, by providing context through the definitions used in 

the fund’s name, combined with the value of the fund’s investments in the 80% basket and 

whether each investment in the fund’s portfolio is in the fund’s 80% basket, investors and the 

 
56  See rule 35d-1 under the Act; see also Names Rule Adopting Release, supra note 10, at section II.E 

(discussing Form N-PORT names rule-related reporting requirements). 
57  See Items B.11 and C.2.e of current Form N-PORT. 
58  In addition, we propose to make conforming changes to General Instruction A of Form N-PORT to remove 

references to these Items. 



48 
 

Commission could use this information to better understand how funds have invested in 

compliance with their 80% investment policies.59 Beyond the Form N-PORT requirements, there 

are other sources of information to help investors, the Commission, and its staff understand how 

a registered fund invests in accordance with the names rule, including fund prospectuses and 

portfolio information. For example, the names rule amendments also require a fund to define the 

terms used in its name, including the criteria the fund uses to select the investments that the term 

describes, in its prospectus. In addition, the amendments require a fund to retain records that are 

available to the Commission and its staff, documenting whether an investment is included in its 

80% basket and, if so, the basis for including that investment in the 80% basket.60  

The Commission considered the costs of reporting requirements in the Names Rule 

Adopting Release. Since then, some funds have begun to work toward implementation of these 

requirements and, in conversations with staff, have raised concerns that the reporting 

requirements are more burdensome than anticipated and may have unintended effects. There are 

operational burdens associated with this reporting, such as building connections between 

different internal and external data systems (including, for example, vendor systems or systems 

of subadvisers) and translating that data from various systems for filing, as well as preparing, 

reviewing, tagging, and filing the information on Form N-PORT. Further, while the names rule 

amendments preserved flexibility for the specific criteria a fund uses to select the investments 

that the term in its name describes, and did not require funds to disclose in their prospectuses 

proprietary criteria used to select investments, reporting on Form N-PORT whether an 

investment is in a registered fund’s 80% basket may provide insight into otherwise proprietary 

 
59  See Names Rule Adopting Release, supra note 10, at sections II.E.1 and II.E.2.  
60  See id. at section II.F. 



49 
 

investment criteria because it will provide specific information about what is included in the 80% 

basket.61 This more specific information may allow other market participants to free ride or front 

run the registered fund’s strategy and may harm fund performance. 

These considerations lead us to propose to eliminate the names rule-related reporting on 

Form N-PORT to avoid potential unintended effects and reduce costs while still providing ways 

for the Commission and the public to understand how a fund invests in accordance with the 

names rule. Although the names-related reporting on Form N-PORT would facilitate the 

Commission’s analysis of a registered fund’s compliance with the names rule, the Commission 

can continue to assess compliance with the names rule through analysis of a fund’s disclosures 

about the terms used in its name, including the criteria the fund uses to select the investments 

that the term describes, combined with portfolio holdings. The Commission also can assess 

compliance with the rule through examinations when appropriate, including by analyzing 

required records documenting whether an investment is included in a fund’s 80% basket and, if 

so, the basis for including that investment in the 80% basket. Although the names rule-related 

reporting on Form N-PORT would provide more specific insight to the public into how funds 

have invested in compliance with their 80% investment policies, the public would continue to 

have access to enhanced disclosures in a fund’s prospectus regarding its 80% investment policy, 

which would provide the public with additional context on the fund’s investments and risks in 

plain English. Finally, the public would continue to have access to information about a fund’s 

 
61  See Names Rule Adopting Release, supra note 10, at n.92 and accompanying text (stating that the amended 

rule provides fund managers with flexibility to ascribe reasonable definitions for the terms used in a fund's 
name and to determine the specific criteria the fund uses to select the investments that the term describes, 
which means a fund would not be required to include proprietary information in its 80% investment policy 
in its prospectus). 



50 
 

portfolio holdings in annual and semi-annual reports, in public Form N-PORT reports, and on 

fund websites. 

With respect to payoff profiles for non-derivatives, the form currently requires registered 

funds to report whether each position is long or short.62 The purpose of the payoff profile 

reporting is to identify short positions held by registered funds, consistent with the current 

requirement in Regulation S-X to disclose investments sold short.63 Under the proposed 

amendment, registered funds would not need to classify non-derivative positions as long or short 

for the purposes of reporting on Form N-PORT. We are proposing to remove this reporting 

because the Commission and the public can use the sign of the value of the holding 

(positive/negative) as a proxy for whether holdings are long or short.64 As a result, removing the 

payoff profile item for non-derivatives would have a limited effect on the utility of Form N-

PORT reports. 

For convertible debt securities, registered funds are required to provide information on 

the conversion ratio as well as the delta (if applicable), among other information.65 The purpose 

of this reporting is to help understand the risk and reward profiles of convertible debt securities. 

We propose to simplify reporting of convertible debt securities by no longer requiring registered 

funds to provide the conversion ratio or delta. We have not found this information as helpful as 

 
62  See Item C.3 of current Form N-PORT. Form N-PORT also allows registered funds to report N/A in this 

field, generally for derivatives because the payoff profiles for derivatives are reported in a separate portion 
of the form. 

63  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.267; 17 CFR 
210.12-12A. 

64  Registered funds report the value of each investment under Item C.2 of Form N-PORT. Funds generally 
report positive values for long positions and negative values for short positions. For example, for Dec. 2024 
filings, only 0.0040% of non-derivative long positions were reported with a negative value and 0.0012% of 
short positions were reported with a positive value. 

65  See Item C.9 of current Form N-PORT. 



51 
 

originally contemplated, and we are able to use information about the underlying reference 

instrument for most of our monitoring and analytical purposes. Moreover, funds may use 

different methodologies for calculating delta for convertible bonds, which adds to variability in 

the reported information and reduces its utility.66 

When reporting liquidity classifications for each portfolio holding, an open-end fund is 

permitted to attribute multiple classifications to a single holding under specified circumstances.67 

Currently, if an open-end fund reports multiple liquidity classifications for a single holding, it is 

required to indicate in its Form N-PORT report which of the three listed circumstances led to the 

use of multiple classifications. We propose to eliminate the requirement that funds indicate a 

reason for reporting multiple liquidity classifications for a single holding. The purpose of this 

requirement was to facilitate more effective Commission monitoring of the liquidity of a fund’s 

portfolio and the ability to determine the circumstances leading to the classification.68 Based on 

our experience with this reporting, it is quite rare for open-end funds to report multiple liquidity 

classifications for a single holding. When funds have reported multiple liquidity classifications 

for a single holding, we have not found the reported reasons to be significantly helpful because 

the circumstances in which open-end funds are permitted to use multiple liquidity classifications 

 
66  Delta information reported on Form N-PORT is nonpublic. As a result, removing the delta for convertible 

debt securities would not affect the public’s use of Form N-PORT information. While the conversion ratio 
is made public, we are not aware of public uses of Form N-PORT information that would be significantly 
affected by the removal of the conversion ratio. 

67  See Instruction to Item C.7 of current Form N-PORT. Specifically, an open-end fund may choose to report 
multiple liquidity classifications for a single holding only in the following circumstances: (1) if portions of 
the position have differing liquidity features that justify treating the portions separately; (2) if a fund has 
multiple sub-advisers with differing liquidity views; or (3) if the fund chooses to classify the position 
through evaluation of how long it would take to liquidate the entire position (rather than basing it on sizes it 
would reasonably anticipate trading).  

68  See Investment Company Liquidity Disclosure, Investment Company Act Release No. 33142 (June 28, 
2018) [83 FR 31859 (July 10, 2018)], at section II.B.1. 



52 
 

for a single holding are limited and specifically outlined in the form.69 As a result, we are 

proposing to remove this requirement. Under the proposal, open-end funds would, however, 

continue to be permitted to report multiple liquidity classifications (if any) under the 

circumstances identified in the form. 

Information on ETF Share Classes and Additional Identifier Information for all 

Registered Funds 

For multiple-class funds that offer an ETF share class, we are proposing to require 

disclosures about the ETF share class’s net assets and flows on Form N-PORT.70 Starting in the 

early 2000s, the Commission granted one fund sponsor exemptive relief to offer an ETF share 

class as one class of an open-end, multi-class fund, subject to various terms and conditions.71 In 

the past few years, the Commission has received many exemptive applications from fund 

sponsors seeking a similar ability to offer ETF share classes. The Commission has begun 

granting exemptive relief in response to these applications.72 As a result, it is likely that ETF 

share classes will grow in number and net assets, and information about ETF share classes’ 

expanding size and flows will become more important. The proposed disclosures would facilitate 

 
69  Liquidity classification information reported on Form N-PORT is nonpublic. As a result, removing this 

item would not affect the public’s use of Form N-PORT information. 
70  Form N-PORT currently requires information on net assets and flows for the registered fund as a whole and 

not on a class-by-class basis. See Items B.1 and B.6 of current Form N-PORT. 
71  See Vanguard Index Funds, et al., File No. 812-12094, Investment Company Act Rel. Nos. 24680 (Oct. 6, 

2000) (notice) and 24789 (Dec. 12, 2000) (order); Vanguard Index Funds, et al., File No. 812-12912, 
Investment Company Act Rel. Nos. 26282 (Dec. 2, 2003) (notice) and 26317 (Dec. 29, 2003) (order); 
Vanguard International Equity Index Funds, et al., File No. 812-12860, Investment Company Act Rel. Nos. 
26246 (Nov. 3, 2003) (notice) and 26281 (Dec. 1, 2003) (order); and Vanguard Bond Index Funds, et. al., 
File No. 812-13336, Investment Company Act Release Nos. 27750 (Mar. 9, 2007) (notice) and 27773 (Apr. 
2, 2007) (order).  

72  See DFA Investment Dimensions Group Inc., Dimensional Investment Group Inc., Dimensional ETF Trust 
and Dimensional Fund Advisors LP, File No. 812-15484, Investment Company Act Release Nos. 35770 
(Sept. 29, 2025) (notice) and 35786 (Nov. 17, 2025) (order).  



53 
 

the Commission’s and the public’s understanding of the growth of the industry and inform any 

future Commission action. 

We are proposing amendments to Form N-PORT to require registered funds with an ETF 

share class to report the following: 

• Size. The amendments would require separate reporting of net asset information for 

the ETF share class.73 

• Flows. The amendments would require separate reporting of information about the 

total net asset value of shares sold and total net asset value of shares redeemed or 

repurchased for the ETF share class.74 

These disclosure requirements are designed to provide investors and the Commission 

information about the ETF share class structure by measuring their net assets and flows, 

separately from the fund as a whole. This information is important because an ETF share class is 

structured and may behave differently than the other share classes in a multiple-class fund. 

Separate information for an ETF share class also would facilitate staff analysis of industry trends 

and risks given these structural differences. As an example, ETFs may present different liquidity 

risks than mutual funds, as shares of an ETF can be traded on an exchange throughout the day 

and, when authorized participants transact with the fund, an ETF is more likely to redeem in kind 

(that is, by delivering certain assets from the ETF’s portfolio, rather than in cash), thereby 

avoiding the need for the ETF to sell assets to meet redemptions.  

Additional Identifying Information 

 
73  See Item B.1.d of proposed Form N-PORT. To identify the ETF share class, funds would be required to 

report the ticker symbol of the ETF share class. 
74  See Item B.6.d of proposed Form N-PORT. 



54 
 

While registered funds are currently required to report certain identifying information on 

Form N-PORT, we are proposing to require funds to provide ticker symbols by registrant, and 

for each class of a registrant or series, as applicable, as well as certain other class-level 

information, if any, to help staff and data users use data more efficiently.75 We recognize that 

when the Commission adopted Form N-PORT, the Commission determined that requiring a 

registered fund to report ticker symbols on Form N-PORT would not be necessary because other 

reported information (e.g., for the registrant, information such as the name, CIK, and LEI; and 

for the series, information such as the name, EDGAR identifier, and LEI) was sufficient for 

Commission staff, as the primary user of Form N-PORT, to identify funds filing reports on Form 

N-PORT, and could also be useful for investors and other potential users.76 However, since then, 

with experience, the staff has found that ticker symbols would enhance the efficiency of data 

analysis.  

For example, staff has observed that matching a registered fund, series, and/or class using 

only its name in multiple data sources (e.g., Form N-PORT reports, other reports such as Form 

N-CEN, and third-party vendor information) can be difficult because of very slight differences in 

the reported name of the fund, series, and/or class. Further, staff has observed that ticker symbols 

are more widely used than LEIs across multiple data sources, and that while LEIs are not 

assigned on the basis of share classes, there are distinct ticker symbols identifying each fund 

share class. Requiring a registered fund to report a ticker symbol associated with the registrant, 

or for each class of the registrant or series, as relevant, would facilitate the ability of the data user 

to conduct comprehensive data analyses across multiple data sources more efficiently, and would 

 
75  See Item A.3 of proposed Form N-PORT. 
76  See Reporting Modernization Adopting Release, supra note 20, at paragraph accompanying n.69. 



55 
 

complement other identifying information that registered funds currently report across other 

reporting forms.77  

We request comment on the proposed amendments to Form N-PORT, including the 

following:  

24. Should we, as proposed, relating to portfolio level risk metrics, increase the 

threshold for determining which registered funds must report risk metrics from 

25% or more of the fund’s net asset value to 50% or more of the fund’s net asset 

value? Should the threshold be lower (e.g., 30% or 40%) or higher (e.g., 60% or 

70%)? In addition to, or separate from, the numerical threshold, should we change 

the period over which the threshold is measured? For instance, instead of 

measuring the average value of the fund’s debt positions for the previous 3 

months, should the period be shorter or longer, such as 1-, 6-, or 12-months? Are 

there other threshold alternatives that would be more effective or appropriate? 

25. Should we, as proposed, remove the requirement to report the DV01 interest rate 

risk metric? Do investors or other members of the public use this information? If 

so, how? Do the benefits of this information to investors or other members of the 

public justify the costs of reporting it? 

26. Should we, as proposed, simplify the reporting of the DV100 interest rate risk 

metric by requiring registered funds to report an aggregate figure across all 

currencies for which the fund had a value of 1% or more of its net asset value, 

 
77  Registered funds currently are required to provide their ticker symbols in other filings with the 

Commission. See, e.g., Item 1 of Form N-1A and Item C.2 of Form N-CEN. By requiring current ticker 
symbol information on Form N-PORT, the proposed amendments would address situations where a 
registered fund, for example, may have changed its ticker symbol information between the fund’s annual 
filings on Form N-CEN and, thus, the ticker information in the fund’s most recent Form N-CEN filing is 
inaccurate. 



56 
 

rather than separately by currency? What effect, if any, would this change have on 

the use of Form N-PORT information by investors or other members of the 

public? In addition to, or separate from these proposed changes, should we 

eliminate the need to report DV100 separately for different maturity buckets (3 

months, 1 year, 5 years, 10 years, and 30 years) and instead require a single 

aggregated DV100 measure? 

27. Should we, as proposed, simplify the reporting of the credit spread risk metrics by 

no longer requiring registered funds to provide separate measures for investment 

grade and non-investment grade exposures? What effect, if any, would this 

change have on the use of Form N-PORT information by investors or other 

members of the public? In addition to, or separate from these proposed changes, 

should we eliminate the requirement to report credit spread risk metrics separately 

for different maturity buckets (3 months, 1 year, 5 years, 10 years, and 30 years) 

and instead require a single aggregated credit spread risk measure? 

28. What is the burden associated with the proposed changes to portfolio level risk 

metrics? How would the reporting burden compare between the current and 

proposed requirements?  

29. Should we, as proposed, require multiple class funds to report returns only for a 

single representative class? Is the proposed method of selecting a representative 

class effective? Should we instead define a representative class as the class with 

the greatest net assets as of the end of the reporting period or give a registered 

fund full discretion to choose a representative class based on considerations such 

as age or size of the class (e.g., by selecting the oldest class or the class with the 



57 
 

greatest net assets), without considering which class has the longest period of 

returns as Form N-1A requires under certain circumstances? How often would the 

representative class change under our proposed approach or potential alternatives? 

Are there other criteria a fund should be permitted or required to use to select its 

representative class? Would the proposed approach of requiring reporting of only 

a single representative class affect how investors or other users of Form N-PORT 

use the reported information? If so, could investors or other users instead use 

return information in fund prospectuses or shareholder reports for individual 

classes? 

30. Should we, as proposed, continue to require registered funds to report monthly net 

realized gain (loss) and net change in unrealized appreciation (or depreciation) 

attributable to derivatives for the listed asset categories (commodity contracts, 

credit contracts, equity contracts, foreign exchange contracts, interest rate 

contracts, and other contracts)? Should we make any changes to the listed asset 

categories? Should we require the aggregate net realized gain (loss) and net 

change in unrealized appreciation (depreciation) for all derivatives positions, 

instead of requiring separate figures for each asset category? 

31. As proposed, should we remove the requirement to report monthly net realized 

gain (loss) and net change in unrealized appreciation (or depreciation) by 

derivative type (forward, future, option, swaption, swap, warrant, and other) 

within each asset category of derivatives? Would removal of this information 

reduce reporting burdens for registered funds? Would removal of this information 

affect investors or other users of Form N-PORT information and, if so, how? 



58 
 

32. Currently, Form N-PORT requires funds to report the notional value for most 

types of derivatives but, for options, requires funds to report the exercise price.78 

In addition, funds must calculate the notional value of derivatives positions for 

purposes of meeting other regulatory requirements.79 When reporting options 

positions on Form N-PORT, should we require registered funds to provide the 

notional value, rather than the exercise price? Would this change streamline 

reporting and reduce reporting burdens (and, if so, by how much)? What effect, if 

any, would such a change have on the public’s use of Form N-PORT information? 

33. Should we, as proposed, eliminate the names rule-related reporting? Do enhanced 

disclosures in fund prospectuses about a fund’s 80% investment policy, along 

with available information about fund portfolio holdings, provide the public with 

sufficient information to understand a fund’s investments and risks? To what 

extent would removing the names rule-related reporting reduce reporting burdens 

for registered funds? Instead of eliminating the names rule-related reporting, are 

there modifications to these requirements we should make? For example, should 

we require a fund to report the value of the fund’s 80% basket, as a percentage of 

the value of the fund’s assets, but remove other names rule-related reporting 

requirements? 

34. Should we, as proposed, eliminate reporting of the payoff profiles of non-

derivatives? Should we, as proposed, eliminate reporting of the conversion ratio 

 
78  See Item C.11.c.v of current Form N-PORT. 
79  17 CFR 270.18f-4 (defining derivatives exposure as the sum of the gross notional amount of the fund’s 

derivatives transactions); Item B.3 of Form N-PORT (requiring funds to use the notional value of certain 
derivatives for which the underlying reference asset or assets are debt securities or an interest rate when 
determining if the fund is required to report portfolio level risk metrics due to the value of its exposure to 
debt instruments). 



59 
 

and delta of convertible debt securities? Would removal of the conversion ratio of 

convertible debt securities affect investors or other uses of Form N-PORT 

information and, if so, how? Should we, as proposed, eliminate reporting of the 

reason an open-end fund has reported multiple liquidity classifications for a single 

investment? What are the burdens of reporting each of the items that we propose 

to eliminate, and how much burden would be eliminated by the proposed 

changes? Are there items that we are proposing to eliminate that we should retain 

and/or modify? If so, what are they, why should we retain or modify them, and 

what should any modifications be?  

35. What is the impact to the public if there is less Form N-PORT data available 

because of these proposed amendments to the form? Please provide examples. 

36. Should we, as proposed, require registered funds with ETF share classes to 

disclose net assets and flows for these share classes separately from information 

for the full fund? Should we amend Form N-PORT to require more or less 

information about ETF share classes? If there is other information that would be 

helpful to the public, provide specific examples of how that information would be 

useful. 

37. Should we, as proposed, require registered funds to provide ticker information by 

registrant or for each class of a registrant or series, as applicable? Should we, as 

proposed, require registered funds to report for any classes of the registrant or 

series the class name and EDGAR class identification number as identifying 

information in Part A? How would the reporting burden compare between the 

current and proposed requirements?  



60 
 

38. Should the Commission eliminate reporting on Form N-PORT related to the 

liquidity of a fund’s investments and, if so, why?80 

39. Are there other Form N-PORT items that we should modify or eliminate? Why 

are the benefits of the reported information to the Commission and the public not 

justified by the costs of reporting the information? 

D. Proposed Transition Period 

We propose to provide a tiered transition period for registered funds to comply with the 

proposed amendments, if adopted, based on fund size. We propose to provide a 12-month 

transition period for larger entities and an 18-month transition period for smaller entities. For 

these purposes, larger entities would be registered funds that, together with other investment 

companies in the same “family of investment companies” (as such term is defined in Item B.5 of 

Form N-CEN), have net assets of $10 billion or more as of the end of the most recent fiscal year. 

Smaller entities would be registered funds that, together with other investment companies in the 

same family of investment companies, have net assets of less than $10 billion as of the end of the 

most recent fiscal year.81 The tiered transition period would provide time for registered funds to 

 
80  See Items B.7 (requiring information related to a fund’s highly liquid investment minimum, if applicable), 

B.8 (requiring information about the percentage of a fund’s highly liquid investments that it has pledged as 
margin or collateral in connection with derivatives transactions classified in non-highly liquid categories), 
and C.7 (requiring the liquidity classification of each portfolio investment) of Form N-PORT. 

81  For the last several years, the Commission generally has used a threshold of $1 billion in net assets for 
differentiating between larger and smaller registered investment companies when providing smaller entities 
with additional time to comply with new requirements. We instead are proposing to use a $10 billion 
threshold for the transition period, based on an analysis of the distribution of assets across funds at different 
net asset thresholds. This $10 billion threshold is designed to be a reasonable means of distinguishing larger 
and smaller entities for purposes of tiered compliance dates for Form N-PORT reporting requirements. We 
estimate that, as of Dec. 2024, 22.9% of registered investment companies would be considered to be 
smaller entities. These smaller entities hold approximately 2.13% of aggregate assets of registered 
investment companies. These estimates are based on data reported on Form N-CEN through Jan. 21, 2025. 
The Commission also recently proposed similar amendments to how it defines “small entity” under the 
Regulatory Flexibility Act for investment companies. See Amendments to the “Small Business” and “Small 
Organization” Definitions for Investment Companies and Investment Advisers for Purposes of the 
Regulatory Flexibility Act, Investment Company Act Release No. 35864 (Jan. 7, 2026) [91 FR 1107 (Jan. 
12, 2026)] (“Small Entity Proposing Release”).61 
 

adjust their internal processes and arrangements with service providers to begin to file Form N-

PORT reports on a monthly basis within 45 days of month end and to modify the information 

that is reported. Registered funds would not need to make adjustments related to publication 

frequency because the proposed amendments align with historic requirements, and the 2024 

amendments have not yet gone into effect.  

At the end of the relevant transition period, registered funds would be required to shift 

from a quarterly filing approach to a monthly filing approach and file reports that conform to the 

amended information requirements.82 We propose to require registered funds to make their first 

monthly filing for the first month of the fiscal quarter that begins after the compliance date. 

Because fiscal quarter ends differ among funds, this approach would result in funds being 

required to file their first monthly reports at different times within a three-month range, 

depending on the date of a fund’s fiscal quarter end. Basing the approach on fiscal quarter end is 

meant to ease the transition from quarterly to monthly filing, as this approach would avoid 

requiring some registered funds to begin to file monthly Form N-PORT reports in the middle of a 

fiscal quarter. As an illustrative example, if the compliance date were in May of a given year, the 

transition period would operate as shown in Table 3. 

Table 3. Illustrative Example of Proposed Transition from Quarterly to Monthly Filings 

with a Hypothetical Compliance Period End in May 

Fund’s Fiscal 
Quarter End 

Last Quarterly Filing First Monthly Filing 

May Filing covering the months of 
March, April, and May would be 

Filing for June would be due within 
45 days of the end of June 

 
82  Once a registered fund shifts from quarterly filing to monthly filing, the fund would also no longer be 

required to maintain records of Form N-PORT information no later than 30 days after the end of each 
month under rule 30b1-9. If the proposal is adopted, we anticipate that registered funds would be required 
to maintain records under that rule until they begin to file reports on a monthly basis, consistent with the 
approach taken in the 2024 amendments. See 2024 Adopting Release, supra note 1, at n.170 and 
accompanying text.  



62 
 

due within 60 days of the end of 
May 

June Filing covering the months of April, 
May, and June would be due within 
60 days of the end of June 

Filing for July would be due 45 
days after the end of July 

July Filing covering the months of May, 
June, and July would be due within 
60 days of the end of July 

Filing for August would be due 
within 45 days of the end of August 

 

In addition, we propose to amend the effective and compliance dates of the Form N-

PORT amendments in the 2024 Adopting Release that would not be superseded by this 

rulemaking to align with the effective and compliance dates for the proposed amendments in this 

release, if adopted. This would include the amendments to entity identifiers to separate the 

concepts of LEI and RSSD ID, as well as technical amendment to the definition of ETF in Form 

N-PORT to include a direct reference to 17 CFR 270.6c-11, the Commission’s exemptive rule 

for ETFs.  

We request comment on the proposed transition period: 

40. Would the proposed transition period provide registered funds enough time to comply 

with the proposed amendments? Should the period be shorter or longer? 

41. Should the transition period differ by fund size, as proposed, or should the transition 

period be the same for all registered funds? Is there a different approach we should 

use for determining fund size for purposes of the transition period? 

42. As proposed, should we change the compliance date for the amendments from the 

2024 Adopting Release that are not being superseded (e.g., the amendments to 

separate the concepts of LEI and RSSD ID) to align with the compliance date for the 

proposed amendments? If the transition period for the 2024 amendments that are not 

being superseded should differ, in what way should it differ? 



63 
 

43. Is the proposed approach for transitioning from quarterly filing to monthly filing 

workable? Would a different approach be more effective? For example, should we 

instead require registered funds to make their first monthly filing for the first month 

preceding the end of the compliance period, meaning registered funds would begin to 

file monthly reports at the same time, regardless of their fiscal year ends? Under this 

approach, if that month is not the beginning of a fund’s fiscal quarter, should we 

require the fund to file information for prior months in that fiscal quarter at the same 

time the first monthly report is due? 

III. Economic Analysis 

A. Introduction 

Reports on Form N-PORT are an important source of information for the Commission 

and its staff. This information helps the Commission monitor industry trends, identify risks, 

inform policy and rulemaking, and assists the staff in examination and enforcement efforts, 

which ultimately benefits investors. In addition, investors and other market participants also 

benefit from the publicly available information that registered funds report on Form N-PORT 

because it aids them in making more informed investment decisions. Currently, the Commission 

receives reports on Form N-PORT on a quarterly basis, no later than 60 days after the end of a 

registered fund’s fiscal quarter, with each quarterly report containing month-end information for 

each month in the quarter, while investors have access to Form N-PORT portfolio data for only 

the third month of a fund’s fiscal quarter.83  

 
83  Monthly portfolio holdings of certain open-end and closed-end funds may also be available on funds’ 

websites, as well as for a fee through third-party data aggregators. Voluntary disclosures of monthly 
portfolio holdings that are currently publicly available may be inconsistent across registered funds and over 
time and may vary in format, presentation, or ease of access. 



64 
 

In 2024, the Commission adopted amendments to Form N-PORT that were intended to 

give the Commission timelier information to conduct comprehensive oversight of the registered 

fund industry, as well as to give investors information to make more informed investment 

decisions.84 Specifically, the 2024 amendments require registered funds to file monthly reports 

within 30 days of month end, replacing the prior approach requiring these funds to file reports 

for each month in a fund’s fiscal quarter no later than 60 days after the end of each fiscal quarter. 

In addition, the 2024 amendments make monthly report information publicly available 60 days 

after month end, which replaces the prior approach of making information for only the third 

month of the fiscal quarter public. The 2024 amendments have yet to be implemented. 

Following adoption of the Form N-PORT amendments, several developments caused the 

Commission to delay the effective and compliance dates of the 2024 amendments and review 

their potential effects.85 As a result of this review, we are proposing to extend the filing deadline 

to 45 days after month end to reduce the costs to registered funds of filing Form N-PORT while 

continuing to provide the Commission with timely data. We are also proposing to publish reports 

for only the third month of a registered fund’s fiscal quarter 60 days after month end to reduce 

the risks to funds and their investors of publishing significantly more information on funds’ 

holdings. In addition, we are proposing to remove or streamline certain items and sub-items of 

the form and to modernize the form to better account for fund structures with ETF share classes. 

The Commission has considered the economic effects of the proposed amendments.86 

Where possible, we have attempted to quantify the economic effects. In some cases, however, we 

 
84  See supra note 1. 
85  See supra section I.A. 
86  Section 2(c) of the Act and section 3(f) of the Exchange Act direct the Commission, when engaging in 

rulemaking where it is required to consider or determine whether an action is necessary or appropriate in, 
 



65 
 

are unable to quantify the economic effects because we lack the information necessary to provide 

a reasonable and reliable numerical estimate. For example, relative to the 2024 amendments, the 

proposed amendments would reduce the amount of information investors have to compare 

registered funds by reverting the frequency of Form N-PORT publication to prior standards. For 

the same reasons we were unable to quantify some of the economic effects associated with the 

increase in publication frequency associated with the 2024 amendments, we are unable to 

quantify these effects as we revert to prior standards in this proposal.87 As described more fully 

below, the Commission is providing both a qualitative assessment and quantified estimate of the 

economic effects, where feasible. 

We request comment on all aspects of the economic analysis of the proposed 

amendments. To the extent possible, we request that commenters provide supporting data and 

analysis on the benefits, costs, and effects on competition, efficiency, and capital formation of 

the proposed amendments or any reasonable alternatives. 

B. Baseline 

The baseline against which the costs, benefits, and the effects on efficiency, competition, 

and capital formation of the proposed rules are measured consists of the current state of the 

 
or consistent with, the public interest, to consider, in addition to the protection of investors, whether the 
action will promote efficiency, competition, and capital formation. In addition, section 23(a)(2) of the 
Exchange Act requires the Commission, when making rules under the Exchange Act, to consider among 
other matters the impact that the rules would have on competition and prohibits the Commission from 
adopting any rule that would impose a burden on competition not necessary or appropriate in furtherance of 
the purposes of the Exchange Act. The analysis below addresses the likely economic effects of the 
amendments, including the anticipated benefits and costs of the amendments and their likely effects on 
efficiency, competition, and capital formation. The Commission also discusses the potential economic 
effects of certain alternatives to the approaches taken in this release. 

87  See 2024 Adopting Release, supra note 1, at paragraph accompanying n.180. 



66 
 

securities markets and the current regulatory framework with respect to registered management 

investment companies and ETFs organized as unit investment trusts (“registered funds”).88 

1. Regulatory Baseline 

Registered funds are required to file periodic reports on Form N-PORT about their 

portfolios and each of their portfolio holdings as of month end. In addition to providing a 

registered fund’s portfolio holdings, Form N-PORT reports also provide information to help 

assess a fund’s risk and return characteristics, such as portfolio level risk metrics, liquidity 

related information, and monthly fund returns for each fund share class.89 Additional 

amendments to Form N-PORT were also adopted in 2023 that would require certain registered 

funds to report information related to their compliance with the names rule after that rule’s 

compliance date.90  

Until the 2024 amendments go into effect, registered funds will continue to file these 

reports on a quarterly basis, with each report due 60 days after the end of a fund’s fiscal quarter. 

While each report includes month-end portfolio information for each month in the relevant fiscal 

quarter, only information about portfolio holdings for the third month of each fiscal quarter is 

made available to the public upon filing; information for the first and second month of each 

 
88  See, e.g., Nasdaq v. SEC, 34 F.4th 1105, 1111–15 (D.C. Cir. 2022). This approach also follows SEC staff 

guidance on economic analysis for rulemaking. See SEC Staff, Current Guidance on Economic Analysis in 
SEC Rulemaking (Mar. 16, 2012), available at https://www.sec.gov/divisions/riskfin/ 
rsfi_guidance_econ_analy_secrulemaking.pdf (“The economic consequences of proposed rules (potential 
costs and benefits including effects on efficiency, competition, and capital formation) should be measured 
against a baseline, which is the best assessment of how the world would look in the absence of the 
proposed action.”); id. at 7 (“The baseline includes both the economic attributes of the relevant market and 
the existing regulatory structure.”).  

89  While the proposed amendments to Form N-PORT would require sales loads and redemption fees to be 
deducted from monthly fund return calculations, some registered funds currently exclude these fees from 
their monthly fund returns on Form N-PORT. This approach is consistent with many funds’ current 
practices and consistent with prior staff guidance. See supra section II.C. 

90  See Names Rule Adopting Release, supra note 10. 



67 
 

fiscal quarter remains confidential. Registered funds are also currently required to maintain the 

data Form N-PORT requires within 30 days of a month end for recordkeeping purposes until the 

2024 amendments go into effect.91  

The 2024 amendments require registered funds to file monthly reports within 30 days of 

month end and the Commission would publish those reports 60 days after month end. The 

subsequent delay of the effective and compliance dates for the 2024 amendments means that 

larger entities must comply with these new requirements as of November 17, 2027, and that 

smaller entities must comply by May 18, 2028. 

Currently, a registered fund may report certain portfolio holdings as miscellaneous 

securities, meaning that information about these holdings can remain nonpublic for up to a year, 

provided that the combined value of the positions reported as miscellaneous securities does not 

exceed 5% of the total value of a fund’s investments and that these positions have not been 

previously disclosed to the public.  

Part F of Form N-PORT also currently requires a registered fund to attach a complete 

schedule of portfolio holdings for the end of the first and third quarters of the fund’s fiscal year, 

presented in accordance with Regulation S-X, within 60 days after the end of the reporting 

period. Further, ETFs, including actively managed ETFs, generally are required to provide full 

portfolio holdings on their websites every business day.92 A small number of “non-transparent” 

ETFs have received exemptive orders from the Commission permitting them not to disclose their 

portfolio holdings on a daily basis. Monthly portfolio holdings of certain registered funds may 

also be available on their websites, as well as through third-party data aggregators (typically for a 

 
91  See rule 30b1-9.  
92  See rule 6c-11(c)(1)(i).  



68 
 

fee), generally on a lagged basis (e.g., 15, 30, 45, or more days after a month end). However, this 

more frequent publication and/or aggregation by third parties of portfolio data is voluntary. 

Currently, most ETFs are structured as individual funds. However, since the early 2000s, 

there have been some mutual funds with ETF share classes. In recent years, the Commission has 

received requests to provide exemptive relief to allow additional mutual funds with ETF share 

classes and the Commission recently began granting exemptive relief.93  

2. Affected Entities 

The proposed amendments to the filing and public disclosure frequency of Form N-

PORT reports would affect all registered funds that are currently required to file reports on Form 

N-PORT. Table 4 below lists registered fund counts along with their net assets by type.94 

 
93  See supra note 72. 
94  Form N-CEN provides census-type information about registered funds, while Form N-PORT provides 

detailed information about fund activities. Because Form N-PORT does not include information about fund 
types, we use information reported on Form N-CEN to estimate the number of affected funds for each type 
of fund. We use information reported to the Commission for each fund as of Dec. 31, 2024, incorporating 
filings and amendments to filings received through May 15, 2025. Net assets are monthly average net 
assets during the reporting period identified on Item C.19.a of Form N-CEN and validated with Bloomberg 
(for ETFs). Current values are based on the most recent filings and amendments, which are based on fiscal 
years and are therefore not synchronous. Submissions of Form N-CEN reports are required on a yearly 
basis. Therefore, these estimates do not include newly established funds that have not completed their first 
fiscal year and, therefore, have not filed on Form N-CEN yet. These estimates also do not account for the 
funds that have been terminated since the last Form N-CEN report was filed. Therefore, the estimates for 
the number of registered funds and their net assets may be over- or under-estimated. 



69 
 

Table 4. Registered Funds Required to File Form N-PORT by Type, as of December 31, 

2024 

Registered Fund Type 
TOTAL 

Number 
Net assets, $ 

trillion 
1. Open-end funds registered on Form N-1A:     
-- a. Mutual funds required to file Form N-PORT1 8,497   $  23.10  
-- b. ETFs:2 3,481   $    7.34 
----- i. non-transparent ETFs3 42 $    0.01 
----- ii. daily website disclosure required4 3,439   $    7.33 
2. Closed-end funds registered on Form N-25 671   $    0.37  
3. ETFs that are UITs registered on Form N-8B-26 4   $    1.00  
4. Variable annuity separate accounts registered on 
Form N-37 15 $    0.27 
Total 12,668 $  32.08 
Notes: 

1. Mutual funds are identified as those funds reported in Item B.6.a of Form N-CEN that are not identified as 
ETFs in Item C.3.a.i of Form N-CEN. Money market funds are excluded from the number of mutual funds, as 
they are not required to file Form N-PORT. We use information reported in Item C.3.g of Form N-CEN to 
identify money market funds and exclude 307 money market funds that hold approximately $6.86 trillion in 
net assets from the total number of mutual funds in order to estimate the number of mutual funds required to 
file Form N-PORT. 

2. ETFs registered as open-ended funds are identified in Item C.3.a.i of Form N-CEN. UIT ETFs and 
exchange-traded managed funds are excluded from these ETF totals and presented in a separate line item. 

3. Non-transparent ETFs are not subject to daily website disclosure of their portfolio holdings. The estimate 
for the number of non-transparent ETFs is based on the staff analysis of funds that have been granted 
exemptive relief to operate actively managed ETFs that do not provide daily portfolio transparency (non-
transparent ETFs). 

4. ETFs identified in Item C.3.a.i of Form N-CEN excluding 42 non-transparent ETFs.  

5. Closed-end funds are identified in Form N-CEN, Item B.6.b. 

6. UIT ETFs are identified in Form N-CEN Item B.6.g, and are also reported in Item E of Form N-CEN. 

7. Variable annuity separate accounts are identified in Form N-CEN, Item B.6.c. 
 

We estimate that there are 12,668 registered funds currently required to file reports on 

Form N-PORT that hold approximately $32.08 trillion in assets (approximately 82% of total 

registered investment companies’ assets). Different types of registered funds may be affected 

differently by the amendments to Form N-PORT. Among the affected funds, there are 8,497 



70 
 

mutual funds that represent approximately 72% of registered funds’ assets, 3,481 ETFs 

registered as open-end funds that represent approximately 23% of registered funds’ assets, 671 

closed-end funds that represent approximately 1.2% of registered funds’ assets, 4 ETFs 

registered as unit investment trusts that represent approximately 3.1% of assets of all registered 

funds, and 15 variable annuity separate accounts that represent approximately 0.8% of assets of 

all registered funds. Among the ETFs registered as open-end funds, 42 are non-transparent ETFs 

with assets of $0.01 trillion and 3,439 are ETFs for which daily website portfolio disclosure is 

required, with assets of $7.33 trillion. 

Of the 12,668 funds required to file reports on Form N-PORT, some registered funds will 

be affected more than others by the proposed amendments to Form N-PORT intended to refine 

the information funds provide.95 30.6% of registered funds representing 25.4% of aggregate net 

assets of N-PORT filers currently report portfolio level risk metrics on Item B.3, while 28.1% of 

registered funds representing 22.5% of aggregate net assets of N-PORT filers have an average 

value of debt securities for the three months prior to December 31, 2024 that exceeds 50% of 

each fund’s net asset value. 47.5% of registered funds representing 62.9% of aggregate net assets 

of N-PORT filers report monthly fund returns for more than one share class on Item B.5.a. 

44.1% of registered funds representing 63.7% of aggregate net assets of N-PORT filers report 

unrealized appreciation (or depreciation) attributable to derivatives in Item B.5.c. All 12,668 

registered funds are required to report payoff profile information for non-derivative positions in 

Item C.3. 0.3% of registered funds representing 1.1% of aggregate net assets of N-PORT filers 

attribute multiple liquidity classification categories to a holding in Item C.7. 5.5% of registered 

 
95  To obtain the percentage of registered funds affected by each Form N-PORT item that follows, we use 

information reported to the Commission on Form N-PORT for each registered fund as of Dec. 31, 2024, 
incorporating filings and amendments to filings received through May 15, 2025. 



71 
 

funds representing 7.8% of aggregate net assets of N-PORT filers report information on 

convertible debt securities in Item C.9.f. Approximately 9,628 registered funds representing 76% 

of registered funds’ assets would be subject to reporting requirements related to their compliance 

with the names rule in Item B.11 and Item C.2.e, once that rule’s compliance period ends.96 

Finally, 69 mutual funds offer an ETF share class, representing 18.9% of aggregate net assets of 

open-end Form N-PORT filers.97 

Table 5 below lists registered fund counts along with their aggregate net assets by fiscal 

year end.98 Among registered funds, there is variation in the fiscal year end. The most common 

fiscal year end used by registered funds is December (26.9% of registered funds), the second 

most common fiscal year end is October (19.0% of registered funds), and August is the third 

most common fiscal year end (8.8% of registered funds).  

Table 5. Registered Funds by Fiscal Year End, as of Dec. 31, 2024 

Fiscal Year End 
Number of Registered 

Funds Net Assets 
# % of total $, trillion % of total 

31-Jan        197  1.5%  $           0.61 1.7% 
28-Feb        398  3.1%  $           2.22  6.1% 
31-Mar     1,116  8.7%  $           3.37  9.3% 
30-Apr        529  4.1%  $           0.99  2.7% 

 
96  See Names Rule Adopting Release, supra note 10, at n.495 and accompanying text. The Commission 

estimated that the names rule would increase the percentage of funds subject to the names rule from 60% to 
76%. We therefore estimate that 9,628 = 76% * 12,668 funds would be affected by the proposed removal of 
Items B.11 and C.2.e on Form N-PORT. 

97  This figure does not reflect recent exemptions, issued by the Commission, permitting additional mutual 
funds to add ETF share classes. See, e.g., DFA Investment Dimensions Group Inc., Investment Company 
Act Release Nos. 35770 (Sept. 29, 2025) (notice) and 35786 (Nov. 17, 2025) (order). 

98  We use information reported on Form N-PORT to the Commission for each registered fund as of Dec. 31, 
2024, incorporating filings and amendments to filings received through May 15, 2025. Fiscal year is 
reported in Item A.3.a of Form N-PORT. Net assets are reported in Item B.1.c of Form N-PORT. We note 
that the total number of the registered funds in this table (12,898 funds) differs from the number based on 
the Form N-CEN data in Table 4 (12,668 funds) because Form N-PORT is submitted on a less delayed 
basis compared to Form N-CEN; thus, it may include newly established funds that have not completed their 
first fiscal year and, therefore, have not filed Form N-CEN yet, as well as funds that have been terminated 
since the last Form N-CEN was filed.  



72 
 

31-May        626  4.9%  $           1.26  3.5% 
30-Jun        816 6.3%  $           1.46  4.0% 
31-Jul        672  5.2%  $           1.28  3.5% 

31-Aug     1,131  8.8%  $           2.78  7.7% 
30-Sep     1,112  8.6%  $           4.03  11.1% 
31-Oct     2,448  19.0%  $           5.89  16.2% 

30-Nov        389  3.0%  $           0.88  2.4% 
31-Dec     3,464  26.9%  $           11.46  31.6% 

TOTAL   12,898  100.0%  $         36.23  100.0% 
 

3. Economic Literature on the Disclosure of Registered Fund Portfolio Holdings 

This section summarizes the academic literature pertaining to the economic effects 

relevant to the changes we are proposing. The Commission has also considered the potential 

economic effects of publicly disclosing registered fund portfolio information in several past 

releases.99 

One strand of the academic literature suggests that the disclosure of holdings can have 

negative economic consequences for a registered fund and its investors. One early study provides 

a theoretical framework showing that, under certain assumptions, “predatory trading” can 

increase trading costs for a large institution (e.g., a fund) when it needs to liquidate a position 

that is known by other market participants.100 Subsequent studies claim that strategies that 

anticipate the sales of mutual funds based on their holdings and predicted outflows, trading 

ahead of them (“front running”), earn excess returns, suggesting that funds incur additional costs 

as a result of these disclosures.101 Several studies also suggest that market participants can “free-

 
99  See supra notes 1, 2, and 20. Those releases also include reviews of the associated academic literature.  
100  See Markus K. Brunnermeier & Lasse Heje Pedersen, Predatory Trading, 60 J. OF FIN. 1825, no.4, 

(2005). 
101  See, e.g., Joshua Coval & Erik Stafford, Asset Fire Sales (and Purchases) in Equity Markets, 86 J. OF FIN. 

ECON.479 (2007); Teodar Dyakov& Marno Verbeek, Front Running of Mutual Fund Fire-Sales (Sept. 6, 
2012) (revised May 1, 2014), 37 J. OF BANKING AND FIN., no.12, 2013 at 4931-4942, available at 
https://ssrn.com/abstract=2170660 retrieved from SSRN Elsevier database. See, also, Sophie Shive & 
Hayong Yun, Are Mutual Funds Sitting Ducks?, 107 J. OF FIN. ECON. 220 (2013). 

https://ssrn.com/abstract=2170660


73 
 

ride” on registered funds by “copycatting” their strategies, earning excess returns without 

incurring the information production costs of the target fund.102 Another study more generally 

finds that while portfolio holdings disclosure by registered funds has beneficial effects, such as 

increased market liquidity, it reduces the returns of otherwise informed funds, noting that such 

costs reduce a fund’s incentive to perform costly research on the securities they invest in.103   

Other studies examine the effect of disclosure on registered fund manager behavior and 

potential agency problems between a fund manager and fund investors. One study suggests that 

more standardized portfolio disclosures can decrease agency problems between funds and 

investors.104 In contrast, another study suggests that more frequent disclosure actually increases 

window-dressing by low-skill fund managers, who try to obfuscate poor performance by 

manipulating their holdings around reporting dates, though more frequent disclosure allows 

investors to sort out skilled from unskilled managers more rapidly.105 

Some studies analyze the effects of portfolio disclosures on issues related to market 

efficiency and capital formation. As noted above, one study suggests that while disclosure is 

 
102  See Mary Margaret Frank, et al., Copycat Funds: Information Disclosure Regulation and the Returns to 

Active Management in the Mutual Fund Industry, 47 J. OF LAW AND ECON., no. 2, 2004 at 515-541; Marno 
Verbeek & Yu Wang, Better Than the Original? The Relative Success of Copycat Funds, 37 J. OF BANKING 
AND FIN. 3454 (2013). 

103  See Vikas Agarwal, et al., Mandatory Portfolio Disclosure, Stock Liquidity, and Mutual Fund 
Performance, 76 J. OF FIN. 2773-2776, (2015) (“Agarwal et al.”). 

104  See Ki-Soon Choi, The Role of Portfolio Disclosures in Mutual Funds (working paper revised Aug. 2 
2023), available at SSRN: https://ssrn.com/abstract=4283140 (retrieved from SSRN Elsevier database). 
The paper analyzes the 2016 adoption of Form N-PORT reporting requirements and suggests that 
standardized portfolio disclosures decreased information asymmetry between fund investors and managers, 
showing that, as a result of the 2016 reporting requirements, fixed-income fund managers (who generally 
have incentives to display lower volatility) became less likely to engage in return smoothing, and equity 
managers became less likely to engage in risk shifting (increasing the risk of a fund portfolio in hopes of 
achieving higher portfolio returns). 

105  See Xiangang Xin, et al., Wrong Kind of Transparency? Mutual Funds’ Higher Reporting Frequency, 
Window Dressing, and Performance, 62 J. ACCT. RSCH.737 (2024); See also Vikas Agarwal, et al., Window 
Dressing in Mutual Funds, 27 REV. OF FIN. STUD, 3133 (2024) for a theoretical model of why managers 
engage in window dressing. 



74 
 

costly for individual funds, it can increase the liquidity of the underlying market for a fund’s 

securities, implying lower trading costs for investors and a lower cost-of-capital for issuing 

firms.106 Another study suggests that quarterly holdings disclosure requirements cause funds to 

alter their trading strategies to conceal their intentions leading up to reporting dates, reducing 

price efficiency around these dates.107 Finally, another study suggests that increased portfolio 

holding disclosure requirements can disincentivize a fund from performing costly research 

activities, reducing price informativeness for firms that the fund invests in and decreasing the 

ability of those firms’ managers to learn from market prices when making real investment 

decisions.108   

C. Benefits and Costs of the Amendments 

1. Filing Timeframe 

We are proposing to amend rule 30b1-9 and Form N-PORT to require registered funds to 

file Form N-PORT reports within 45 days after the end of the month to which they relate.109 

Specifically, rather than filing monthly reports with the Commission within 30 days after the end 

of each calendar month as finalized in the 2024 Adopting Release, we are proposing to require 

registered funds to file reports on a monthly basis due within 45 days after the end of the month 

to which they relate. As a result, the proposed approach would provide registered funds with 

more time to gather and verify the information required to be filed on Form N-PORT and to 

submit the filing. 

 
106  See Agarwal et al., supra note 103. 
107  See Todd A. Gormley, et al., More Informative Disclosures, Less Informative Prices? Portfolio and Price 

Formation Around Quarter-Ends, 146 J. OF FIN. ECON. 665 (2022). 
108  See Jalal Sani, et al., Spillover Effects of Mandatory Portfolio Disclosures on Corporate Investment, 76 J. 

OF ACCT. & ECON. 101641 (2023).  
109  See supra note 11. 



75 
 

The primary benefit of the revised 45-day filing deadline would be to reduce the costs 

that funds might otherwise incur in gathering, verifying, and ultimately filing Form N-PORT on 

a monthly basis under the 2024 amendments. The associated cost savings may be passed on to 

fund investors. While funds will still incur costs associated with gathering and reviewing Form 

N-PORT information, the additional 15 days they have to do so might reduce, for example, the 

number of personnel some funds require. Similarly, while funds will still incur costs associated 

with data validation and data tagging, third-party service provider fees, personnel costs, and 

internal costs associated with developing and maintaining systems, processes, and procedures to 

file form N-PORT on a monthly basis,110 the additional 15 days may reduce the number of 

personnel required to file Form N-PORT each month for some funds. The 45-day filing deadline 

would also reduce any potential costs associated with increased errors and resubmissions under a 

30-day filing deadline.111 The 2024 Adopting Release also stated that some registered funds, 

such as those belonging to smaller fund groups that may not experience economies of scale, may 

experience higher costs associated with a 30-day filing deadline. Consistent with this analysis, 

we would expect that cost reductions associated with the proposed 45-day filing deadline to 

particularly benefit such funds. Finally, during staff outreach following the 2024 Adopting 

Release, industry participants have indicated that registered funds with more complex strategies 

and certain types of closed-end funds, such as those that only strike net asset values once per 

month, may not receive certain data until shortly before the 30-day deadline, increasing the 

potential for errors and resubmissions and potentially causing some registered fund industry 

 
110  See 2024 Adopting Release, supra note 1, at nn. 204-206 and accompanying text for a more detailed 

discussion of these effects. 
111  See id. at nn. 221-223 and accompanying text. See also ICI Letter at note 23. 



76 
 

participants to hire additional personnel to manage the condensed timeframe.112 The 45-day 

filing deadline would mitigate these costs for such funds.  

The proposed 45-day filing deadline would delay the Commission’s receipt of monthly 

Form N-PORT filings by 15 days. As discussed in the 2024 Adopting Release, the timely receipt 

of Form N-PORT information allows the Commission to conduct targeted and timely monitoring 

efforts, to accurately analyze risks and trends, and to assess the breadth and magnitude of 

potential impacts of market events and stress affecting particular issuers, asset classes, 

counterparties, or market participants.113 Therefore, the benefits associated with timely 

Commission oversight, such as reduced investor harm or market disruptions, may decrease as a 

result of the 15-day delay. However, the Commission would still have more timely access to 

registered fund information than it does under the quarterly filing requirements that are currently 

in effect. 

2. Publication Frequency 

We are proposing to require public disclosure of registered funds’ portfolio holdings for 

the third month of each fiscal quarter with a 60-day delay. While the proposal would reduce the 

amount of information available to investors about registered fund holdings relative to the 

monthly portfolio disclosure required by the 2024 amendments, it would also reduce the risk that 

a fund’s proprietary investment strategy or trading intentions are inferred by external parties. 

The primary benefits of the proposed decrease in publication frequency would be to 

reduce certain costs that an increased publication frequency could impose on registered funds.114 

The monthly publication frequency required by the 2024 amendments would provide market 

 
112  See supra section II.A and paragraph accompanying n.13. 
113  See 2024 Adopting Release, supra note 1, at n. 198 and accompanying text. 
114  See id. at n. 237 and accompanying text. 



77 
 

participants with four times more data annually regarding a registered fund’s holdings, 

increasing the risk that a fund’s proprietary investment strategy could be copied by funds that do 

not incur the information production costs of the target fund, and may reduce the returns of the 

target fund.115 In addition, because the 2024 amendments reduce the maximum potential time 

that a registered fund can use to, for example, build a position in a new fund holding from 

approximately five months to approximately three months, funds that tend to establish or dispose 

of positions over periods of time longer than three months risk having their trading intentions 

inferred sooner than is the case under the rules currently in effect.116 While a registered fund’s 

trading intentions or the information on which it is basing its proprietary investment strategy may 

be reflected in the market through other channels, such as the trades a fund initiates in the 

interim, the revelation of a fund’s holdings via Form N-PORT before it has fully established or 

disposed of a position could increase the associated trading costs and reduce returns for its 

investors.117 The proposed changes to the publication frequency would therefore reduce any 

trading costs associated with the publication of registered fund holdings on Form N-PORT. 

While the 2024 Adopting Release acknowledged that increasing the publication 

frequency of Form N-PORT could affect a registered fund’s business practices by, for example, 

altering the fund’s trading strategy around disclosure dates,118 market participants have since 

reiterated the potential costs that the more frequent publication of holdings could impose on 

 
115  See supra notes 102-103 and accompanying text. 
116  Under the requirements prior to the 2024 amendments, if a registered fund, for example, begins to establish 

a new position immediately after quarter-end, the position will not be publicly disclosed for 3 months and 
60 days (i.e., about 5 months in total). Under the 2024 amendments, if a registered fund begins to establish 
a new position immediately after quarter-end, the position will not be publicly disclosed for 1 month and 60 
days (i.e., about 3 months in total). 

117  See 2024 Adopting Release, supra note 1, at n. 240 and accompanying text. 
118  See id. at n. 248. 



78 
 

actively managed funds and their shareholders, and the subsequent need funds may have to alter 

their investment strategies to mitigate these costs.119 These costs could also lead a registered 

fund to decrease its research expenditures or, in the extreme, conclude that a given investment 

strategy is not viable and stop offering it, which could decrease price efficiency as well as 

investor choice.120  

The costs of the proposed amendments include the loss of several benefits to investors 

and other users of Form N-PORT associated with a monthly publication frequency 60 days after 

the end of each reporting period, such as an enhanced ability of investors to review and monitor 

information on registered funds’ portfolios (directly or through analyses performed by third-

party data aggregators). These forgone benefits would include a reduced need to rely on 

registered funds’ voluntary holdings disclosures, which are not consistently provided by all 

registered funds and, even where they are, may have formats that are inconsistent across time or 

across funds, or may be difficult to access.121 In addition, voluntary disclosures do not 

necessarily contain other potentially useful information that is contained on Form N-PORT, such 

as a registered fund’s net assets, liabilities, flows, interest rate risk, credit risk, or counterparty 

risk. Moreover, even where market participants use quarterly Form N-PORT data, registered 

funds report these data in accordance with their own fiscal years, which may differ and preclude 

the comparison of different funds at a given point in time.122 Finally, to the extent more frequent 

Form N-PORT disclosures would have ameliorated agency problems that may exist between a 

registered fund’s manager and the fund’s investors, any benefits investors would have accrued 

 
119  See ICI Letter. 
120  See supra section III.B.3.  
121  See 2024 Adopting Release, supra note 1, at n. 231. 
122  See id. at 73784 (Table 2). 



79 
 

due to a reduction in these agency problems under the 2024 Amendments would no longer 

apply.123 

3. Other Proposed Amendments to Form N-PORT 

We are also proposing amendments to Form N-PORT to refine the information registered 

funds provide. Specifically, we are proposing to modify certain information collected on 

portfolio level risk metrics and returns to narrow their scope, and proposing to eliminate certain 

information collected on non-derivatives instruments’ payoff profiles, convertible bonds, names 

rule compliance, and the reason a single holding has multiple liquidity classifications. We are 

also proposing to modify how funds with ETF share classes report net assets and shareholder 

flows to require separate information for ETF share classes. Finally, we are proposing to require 

registered funds to provide ticker symbols by registrant, and for each class of a registrant or 

series, as applicable, as well as certain other class-level information, if any, to help staff and data 

users use data more efficiently. Throughout this discussion, when we refer to the potential use of 

Form N-PORT by investors, we note that investors may use the information directly or by 

relying on third parties that aggregate the information available on Form N-PORT and provide it 

to investors and other market participants. We also generally refer to the costs (or cost savings) 

associated with the proposed changes as being incurred by, or accrued to, a fund, but note that all 

of the costs or cost savings discussed below may be passed onto fund investors. 

The proposed modifications to the information collected on portfolio level risk metrics 

include an increase in the threshold percentage of registered fund assets held in debt or debt 

derivatives that triggers risk metric reporting requirements, the removal of risk metrics 

 
123  See id. at nn. 234-236 and accompanying text for a discussion of potential agency problems that may be 

mitigated by more frequent portfolio disclosure.   



80 
 

associated with small changes in interest rates (DV01), the aggregation of risk metrics associated 

with larger changes in interest rates (DV100) (rather than separate DV100 reporting for each 

currency that a registered fund has holdings of that amount to 1% or more of the fund’s net asset 

value), the aggregation of credit risk metrics for investment-grade and non-investment grade into 

a single credit risk metric, and a clarification that risk metrics are reported in US dollars. These 

changes would reduce the costs associated with reporting risk metrics on Form N-PORT by 

reducing the number of registered funds that are required to report the metrics, removing certain 

metrics (DV01), and streamlining the reporting of the remaining metrics. To the extent investors 

currently rely on the risk metrics that will be removed or streamlined, the amendments would 

reduce the amount of information on which investors can base their investment decisions. We do 

not expect these changes to significantly affect the utility of the reported information about 

portfolio risk metrics to the Commission.124  

The proposed modifications to the information collected on registered fund returns would 

require that funds with multiple share classes only report return information for a single 

representative class, rather than reporting returns for each share class. This change should reduce 

the costs associated with filing such return information while still providing investors and the 

Commission with fundamental information on a registered fund’s monthly returns. In addition, 

the proposed changes would exclude sales loads and redemption fees from monthly return 

calculations, which would remove the ambiguous effect that these fees have on such monthly 

returns for investors who hold a fund for different lengths of time. Investors would still have 

access to return information reflecting sales loads and redemption fees over several hypothetical 

holding periods for relevant registered funds on Forms N-1A and N-3, and these fees are 

 
124  See supra note 43 and subsequent text.81 
 

explicitly disclosed in a fund’s prospectus. In addition, some registered funds already exclude 

sales loads and redemption fees from their monthly fund returns on Form N-PORT, so we do not 

expect the removal of these fees from monthly return calculations to impose significant costs on 

investors.125   

While registered funds would continue to report the net realized gain and net change in 

unrealized appreciation attributable to derivatives for multiple asset categories, funds would no 

longer be required to separately report this information for each type of derivative within each 

asset category, reducing reporting costs for funds. To the extent investors currently rely on the 

more granular reporting by derivative type within each asset category, the amendments would 

reduce the amount of information on which investors can base their investment decisions. 

In addition, the proposed changes would remove several items from Form N-PORT 

altogether, which would reduce reporting costs for registered funds. For positions that are not 

derivatives, registered funds would no longer have to classify the payoff profile (long, short, or 

N/A) of the position. While the explicit item capturing the payoff profile of such positions would 

no longer be available to investors, investors would still be able to determine a position’s payoff 

profile from the sign of the corresponding holding reported on Form N-PORT. We are also 

proposing to remove both the conversion ratio and the delta for convertible debt securities from 

Form N-PORT. To the extent investors rely on the conversion ratio information, they will have 

less information on which to base their investment decisions. In addition, the proposed changes 

would no longer require an open-end fund that is attributing multiple liquidity classifications to a 

holding to indicate the reason the holding requires multiple classifications. Because liquidity 

classifications are not publicly reported, this change would not impose costs on investors.  

 
125  See supra note 89. 



82 
 

The proposed changes discussed above either reduce the content of, or eliminate, certain 

items from Form N-PORT, which will reduce the amount of information available to the 

Commission for oversight purposes. However, based on our experience, not having this data 

would not adversely affect our oversight capabilities, so we do not expect them to reduce 

investor protections. 

In addition to the Form N-PORT items that we are proposing to remove or streamline 

based on Commission experience using the information provided by registered funds on Form N-

PORT, we are also proposing to remove three items from Form N-PORT that were adopted as 

part of amendments to the names rule, which funds have not yet begun to report.126 These 

disclosures apply to registered funds required to adopt an 80% investment policy and include: (1) 

definitions of terms used in the fund’s name; (2) the value of the fund’s 80% basket, as a 

percentage of the value of the fund’s assets; and (3) whether each investment in the fund’s 

portfolio is in the fund’s 80% basket.127 Removing these items would eliminate the costs 

registered funds would incur associated with modifications to internal compliance systems, the 

potential use of third-party service providers in filing these items, and the need to add new data 

tags for these items for purposes of filing the names rule relevant items on Form N-PORT.128 

While the Commission would still be able to perform oversight of a fund’s compliance with the 

names rule due to the rule’s recordkeeping and other disclosure requirements, the removal from 

Form N-PORT of individual holding classifications under the names rule as well as the aggregate 

value of a fund’s 80% basket could reduce the efficacy of the Commission’s oversight, such as 

its ability to conduct targeted exams. In addition, to the extent that investors would have relied 

 
126  See Names Rule Adopting Release, supra note 10. 
127  See Items B.11 and C.2.e of current Form N-PORT. 
128  See Names Rule Adopting Release, supra note 10, at paragraphs accompanying nn.571-574. 



83 
 

on the information on Form N-PORT regarding names rule compliance, either directly or 

through third parties, to better determine whether or not a registered fund’s investment strategy is 

consistent with their goals and preferences, the removal of these items would reduce their ability 

to do so. For a fund with an 80% investment policy, investors would still have access to the 

definition of terms used in the fund’s name and any selection criteria associated with these terms 

in the fund’s prospectus, as well as information about the fund’s portfolio holdings, which may 

mitigate this effect. 

The proposed changes to Form N-PORT also include a new item tailored to registered 

funds with ETF share classes. Funds with ETF share classes would be required to provide 

identifying information for the share class, information on the net assets associated with the 

share class, and information on flows into and out of the share class. Investors and market 

participants would benefit from these changes by gaining a more detailed understanding of the 

differences in size and flows of a fund’s ETF and non-ETF share classes, particularly if the 

number of funds offering ETF share classes increases. Finally, these changes would allow the 

Commission to monitor and respond to any issues that arise if the number of registered funds and 

the amount of assets managed using ETF share classes increase in the future. Funds that have an 

ETF share class would incur costs associated with identifying, validating, and filing these new 

items on Form N-PORT. 

Finally, we are proposing to require registered funds to provide ticker symbols by 

registrant, and for each class of a registrant or series, as applicable, as well as certain other class-

level information, if any, to help staff and data users use data more efficiently.129 As discussed 

above, using the identifying information that registered funds currently report to match a fund, 

 
129  See supra note 75. 



84 
 

series, and/or class across multiple data sources (e.g., Form N-PORT reports, other reports such 

as Form N-CEN, and third-party vendor information) can be difficult because of slight 

differences in the reported name of the fund, series, and/or class as well as the lack of LEIs or 

EDGAR series identifiers in some data sources.130 The additional identifying information 

required for registrants and each class of a registrant or series would improve the Commission’s 

ability to monitor and analyze registered fund activity across data sources, enhancing investor 

protections. The additional identifying information would also improve the ability of investors to 

compare funds and individual share classes and series across different data sources, allowing 

them to make more informed investment decisions. Registered funds would incur costs 

associated with validating and filing these new items on Form N-PORT. 

4. Monetized Benefits and Costs 

This section estimates the monetized benefits and costs of the proposed amendments by 

disaggregating the net reduction in PRA burden discussed in section IV.131  These estimates are 

then used in the following section to calculate present and annualized values of the benefits and 

costs of the proposed amendments under different discount rate assumptions. These estimates are 

expected to be lower bounds on the benefits and costs registered funds and their investors would 

experience because we are not able to quantify all of the economic effects of the proposed 

changes.132 

 
130  See supra note 77 and preceding discussion. 
131  The monetization in this section reflects the reduction in PRA burden discussed in section IV. As noted 

there, this reduction includes consideration of the additional costs that would be imposed by adding 
information about ETF share classes and by adding additional identifying information. See infra note 162. 
Also note that while we estimate that 9,628 funds would be affected by names-rule related changes to Form 
N-PORT in section III.B.2, the cost saving estimates reflect the number of funds (9,926) used to calculate 
the associated PRA burden (see section IV, Table 8, note 7). 

132  See supra note 87 and preceding discussion. 



85 
 

We estimate that registered funds would experience net one-time cost savings of 

$94,013,000 associated with the change in filing timeframe from 30 days to 45 days and the 

various amendments to Form N-PORT.133 These one-time cost savings are net of the aggregate 

one-time costs of $2,923,142 that we estimate are associated with the information about ETF 

share classes and the additional identifying information that would be required by the proposed 

amendments.134 Therefore, we estimate that registered funds would benefit from gross one-time 

costs savings of $96,936,142 as a result of the proposed amendments.135 

Similarly, we estimate that registered funds would experience net ongoing cost savings of 

$95,955,431 associated with the change in filing timeframe from 30 days to 45 days and the 

various amendments to Form N-PORT.136 These ongoing cost savings are net of the aggregate 

 
133  See section IV, Table 8. Registered funds that license a software solution to file Form N-PORT are 

expected to experience aggregate one-time cost savings of $6,105,618 (4,434 funds * 3 hours * $459 per 
hour), while those that outsource filing Form N-PORT to a third-party are expected to experience aggregate 
one-time cost savings of $11,338,218 (8,234 funds * 3 hours * $459 per hour). In addition, registered funds 
affected by the names rule are expected to experience one-time aggregate cost savings of $76,569,164 
(9,926 funds * 19 hours * $406 per hour). Total aggregate one-time cost savings based on the information 
in Table 8 are therefore expected to be $94,013,000 ($6,105,618 + $11,338,218 + $76,569,164). Note that, 
while we estimate that 9,628 funds will be affected by names-rule related changes to Form N-PORT in 
section III.B.2, these cost estimates reflect the number of funds used to calculate the associated PRA 
burden (see section IV, Table 8, note 7). 

134  As noted in section III.B.2, we estimate that 69 registered funds would be required to file information about 
ETF share classes. We estimate that these registered funds would incur an initial burden of 0.5 hours 
associated with filing ETF information at a blended wage rate of $459 per hour, implying initial aggregate 
costs of $15,836 (69 funds * 0.5 hours * $459 per hour). All 12,668 registered funds currently required to 
file reports on Form N-PORT would be required to file the additional identifying information, and we 
estimate that these funds would incur an initial burden of 0.5 hours at a blended wage rate of $459 per hour, 
implying initial aggregate costs of $2,907,306 (12,668 funds * 0.5 hours * $459 per hour). Total aggregate 
one-time costs associated with the additional information we are requiring on Form N-PORT are therefore 
expected to be $2,923,142 ($15,836 + $2,907,306). 

135  $96,936,142 = $94,013,000 + $2,923,142. 
136  See section IV, Table 8. Note that internal annual burden hours reported in the table include initial burden 

estimates annualized over a 3-year period. To isolate ongoing economic burden hours, we thus reduce the 
internal annual burden hours by one third of the initial internal burden hours, both as reported in Table 8. 
Registered funds that license a software solution to file Form N-PORT are expected to save $6,105,618 
(4,434 funds * 3 hours * $459 per hours) in aggregate annually due to a reduction in internal hours spent 
filing Form N-PORT and to save $4,434,000 (4,434 funds * $1,000 per fund) from reduced costs associated 
with external services. Similarly, registered funds that outsource filing Form N-PORT to a third-party are 
expected to save $7,558,812 (8,234 funds * 2 hours * $459 per hour) in aggregate annually due to a 
 



86 
 

ongoing costs of $1,461,571 that we estimate are associated with the information about ETF 

share classes and the additional identifying information that would be required by the proposed 

amendments.137 Therefore, we estimate that registered funds would benefit from gross ongoing 

costs savings of $97,417,002 as a result of the proposed amendments.138 

5. Present Values and Annualized Values of Monetized Benefits and Costs 

In this section, we report the total monetized benefits and costs of the proposed 

amendments, as calculated in the previous section, in two additional ways. These presentations 

are intended to address the fact that the various benefits and costs of the proposed amendments 

would not accrue at the same point in time; rather, benefits and costs that accrue sooner are 

generally more valuable than those that occur later in time. Specifically, we report below: (1) the 

present values of expected benefits and costs that are monetized in our economic analysis over a 

10-year time horizon, starting in 2026, as well as (2) the annualized values over the same time 

horizon that are derived from the present values. This 10-year time horizon represents the period 

over which the principal benefits and costs that are monetized in the economic analysis are 

 
reduction in internal hours spent filing Form N-PORT and to save $16,468,000 (8,234 funds * $2,000) 
from reduced costs associated with external services. In addition, registered funds affected by the names 
rule are expected to experience annual cost savings of $38,956,241 (9,926 funds * 9.67 hours * $406 per 
hour) due to a reduction in internal hours spent filing names-related information on Form N-PORT and to 
save $22,432,760 (9,926 funds * $2,260) from reduced costs associated with external services. Total 
aggregate cost savings are therefore expected to be $95,955,431 ($6,105,618 + $4,434,000 + $7,558,812 + 
$16,468,000 + $38,956,241 + $22,432,760). 

137  As noted in section III.B.2, we estimate that 69 funds would be required to file information about ETF 
share classes. We estimate that these registered funds would spend an additional 0.25 hours annually 
associated with filing ETF information at a blended wage rate of $459 per hour, implying ongoing 
aggregate annual costs of $7,918 (69 funds * 0.25 hours * $459 per hour). All 12,668 registered funds 
currently required to file reports on Form N-PORT would be required to file the additional identifying 
information, and we estimate that these funds would spend an additional 0.25 hours annually at a blended 
wage rate of $459 per hour, implying ongoing aggregate annual costs of $1,453,653 (12,668 funds * 0.25 
hours * $459 per hour). Total aggregate annual costs associated with these changes are therefore expected 
to be $1,461,571 ($7,918 + $1,453,653).  

138  $97,417,002 = $95,955,431 + $1,461,571. 



87 
 

expected to accrue.139 The present values and annualized values account for the timing of 

benefits and costs through discounting, which is a procedure that accounts for the time value of 

money.140 The present values and annualized values are computed for total monetized benefits 

and costs, combining one-time and recurring monetized benefits and costs, across all affected 

entities over the time horizon. 

Table 6 reports the present values of monetized benefits and costs using annual real 

discount rates of 3 percent and 7 percent over a 10-year time horizon, starting in 2026.141  

Table 6. Present Value of Monetized Benefits and Costs  

Over a 10-year Time Horizon (in 2025 $)1  

Estimated Effects2 3% real discount rate 7% real discount rate 
Benefits $844,307,797 $710,518,371 

Costs $14,136,138 $12,128,864 
 

1   This Table includes only benefits and costs that are monetized. As discussed in this economic analysis, there are 
other benefits and costs that we are not able to monetize. 

2   For each discount rate, the present value of monetized benefits or costs is calculated assuming that: (i) all one-time 
monetized implementation benefits and costs are immediately incurred (i.e., these costs are not discounted); (ii) 
recurring annual monetized benefits and costs start to be incurred as of the year in which affected entities first 
comply. In (iii), we assume that monetized benefits and costs accrue mid-year, and we use a mid-year discount rate. 
We are proposing a 12-month transition period for larger entities and an 18-month period for smaller entities. 
Correspondingly, both groups of entities would start complying with the proposed rule in the same calendar year 
(2027 for the purposes of this calculation), and we therefore discount the cash flows for both entities at mid-year of 
the same calendar year in our present value calculations. 

 
139  See OMB, CIRCULAR A-4, at 31-34 (Sept. 17, 2003) at 31 (stating that “[t]he ending point should be far 

enough in the future to encompass all the significant benefits and costs likely to result from the rule”). For 
the purposes of this analysis, we assume the effective date of the rule, as well as the start year for the 
analysis’s 10-year time horizon, is the present year. The analysis uses calendar years and also accounts for 
the compliance periods included in the release (see note 2 in Table 6). 

140  See id. at 32 (“The Rationale for Discounting”) and 45 (“Treatment of Benefits and Costs over Time”). See 
also OIRA, REGULATORY IMPACT ANALYSIS: A PRIMER, at 11 (Aug. 15, 2011), available at 
https://www.reginfo.gov/public/jsp/Utilities/circular-a-4_regulatory-impact-analysis-a-primer.pdf (“To 
provide an accurate assessment of benefits and costs that occur at different points in time or over different 
time horizons, an agency should use discounting. Agencies should provide benefit and cost estimates using 
both 3 percent and 7 percent annual discount rates expressed as a present value as well as annualized.”). 
See also, e.g., HARVEY S. ROSEN & TED GAYER, PUBLIC FINANCE 151 (8th ed. 2008) (defining present 
value as “the value today of a given amount of money to be paid or received in the future”). 

141  This approach is consistent with OMB Circular A-4. See id at 31-34 (stating that, “[f]or regulatory analysis, 
[agencies] should provide estimates of net benefits using both 3 percent and 7 percent” discount rates and 
discussing why those rates are reasonable default rates).  

https://www.reginfo.gov/public/jsp/Utilities/circular-a-4_regulatory-impact-analysis-a-primer.pdf


88 
 

 

Table 7 reports annualized monetized benefits and costs using real discount rates of 3 

percent and 7 percent over a 10-year horizon, starting in 2026.142 The lump sum present values of 

monetized benefits and costs reported in Table 6 are converted in Table 7 into a constant stream of 

annualized benefits and costs over a 10-year time horizon.143 Annualized benefits and costs may 

differ from any recurring annual benefits and costs discussed earlier in this economic analysis 

because they incorporate the timing of benefits and costs, through discounting, and combine one-

time and recurring benefits and costs.144  

Table 7. Annualized Monetized Benefits and Costs over a 10-year Time Horizon (in 2025 $) 1  

Estimated Effects2 3% real discount rate 7% real discount rate 
Benefits $97,526,543 $97,796,834 

Costs $1,632,875 $1,669,435 
 

1   This Table includes only benefits and costs that are monetized. As discussed in this economic analysis, there 
are other benefits and costs that we are not able to monetize. 

2   For each discount rate, the annualized value of monetized benefits (costs, respectively) is calculated by 
dividing the corresponding present value of monetized benefits (costs, respectively) in Table 6 by the sum of 
discount factors over the 10-year time horizon. The discount factor in year t of the 10-year time horizon (t = 1, 
…, 10) is equal to 1 / (1 + discount rate)^(t-0.5)), where the discount rate is either 3% or 7%. The sum of 
discount factors over the 10-year time horizon is then the sum of the discount factors across years t = 1 
through 10. 

 

In sum, Tables 6 and 7 report in two alternative ways expected total benefits and costs, 

across all affected entities, which are monetized in our economic analysis, using real discount rates 

of 3 percent and 7 percent over a 10-year time horizon. 
 

 
142  This approach is consistent with the recommended treatment of benefits and costs over time in Circular A-

4. See id. at 45 (“You should present annualized benefits and costs using real discount rates of 3 and 7 
percent”). 

143  For each discount rate, the annualized monetized benefits (costs, respectively) in Table 7 represent the 
constant annual stream of benefits (costs, respectively) whose present value over the 10-year horizon 
equates the corresponding present value in Table 6. See note 2, Table 7 for additional calculation details. 

144  The annualized benefits and costs present these values over the 10-year time horizon, starting in the present 
year, even if recurring annual benefits and costs would actually start to be incurred at a later date due to 
compliance periods.  



89 
 

D. Effects on Efficiency, Competition, and Capital Formation 

1. Efficiency 

By reducing the frequency at which a registered fund’s portfolio holdings are disclosed 

on Form N-PORT relative to the 2024 amendments, the proposed amendments reduce the risk 

that external parties infer the fund’s proprietary investment strategy or trading intentions and use 

that information in ways that increase costs for the fund and its shareholders.145 Under the 2024 

amendments, concerns about such costs could cause registered funds to alter their business 

practices in ways that reduce information production,146 potentially reducing the price efficiency 

of the securities funds hold.147 Specifically, a registered fund might decide to reduce its 

investment in researching securities if the fund expects the returns to performing such research 

will be reduced by increased disclosure of the fund’s holdings on Form N-PORT, or to forgo an 

investment strategy altogether. To the extent that the potential costs associated with more 

frequent portfolio disclosure under the baseline would cause registered funds to reduce their 

information production, the proposed amendments would eliminate this disincentive, increasing 

price efficiency. 

The proposed changes would reduce the frequency and consistency of registered fund 

holding disclosures, which could reduce the ability of investors to monitor funds’ portfolios and 

make investment decisions that are more aligned with their objectives and risk tolerance, 

decreasing allocative efficiency.148 In addition, price efficiency might decrease if investors 

would have used the more frequent disclosure of registered fund holding valuations contained on 

 
145  See supra notes 115 to 117. 
146  See supra notes 118 to 119. 
147  See 2024 Adopting Release, supra note 1, at section IV.D.1. 
148  See id. at n. 260. 



90 
 

Form N-PORT (which may be useful for holdings that are not traded on an exchange) and the 

knowledge that certain registered funds are holding a particular security to inform their 

investment decisions under the baseline.149 Finally, price efficiency in the secondary market for 

shares of closed-end funds could be reduced to the extent that investors would have used the 

more frequent disclosure of closed-end fund holdings to better value these shares prior to 

transacting in the secondary market.150 

The other proposed amendments to Form N-PORT are not expected to have significant 

effects on efficiency, competition, or capital formation. If anything, they may have a marginal 

effect on allocative efficiency to the extent they change the information available to investors in 

selecting investments that match their objectives or risk preferences. For example, additional 

information on the net assets and shareholder flows for ETF share classes as well as more robust 

identifying information for fund registrants, share classes, and series may allow investors to 

make marginally more efficient investment decisions. In contrast, the elimination of certain 

information as well as the narrowing of scope for other information may marginally reduce the 

efficiency of investors’ investment decisions. In the latter case, any marginal negative effects on 

investment efficiency may be mitigated by the continuing availability of relevant information 

elsewhere on Form N-PORT or in other filings. For example, investors or third parties may be 

able to compute certain items that are being streamlined or removed from Form N-PORT directly 

from registered funds’ published quarterly holdings. In such cases, the effect of the proposed 

changes would be limited to a decrease in such information during the two months between 

quarters during which holdings are reported. 

 
149 See id. at nn. 262-263 and accompanying text. 
150  See id. at discussion in last paragraph of section IV.D.1. 



91 
 

2. Competition 

By increasing the time registered funds have to file Form N-PORT from 30 days to 45 

days, the proposed amendments would mitigate compliance costs that, as a percentage of assets 

under management, likely would have been higher for smaller funds and fund complexes.151 In 

doing so, the proposed amendments could increase, relative to the 2024 amendments, these 

smaller funds’ ability to compete with larger funds and fund complexes. Similarly, to the extent 

that registered funds would have passed on compliance costs associated with the 2024 

amendments to their investors, the proposed changes would mitigate any reduction in the 

competitiveness of registered funds relative to other investment vehicles such as collective 

investment trusts or separately managed accounts.152  

To the extent that the increased frequency and consistency of the information investors 

would have had about registered fund holdings under the 2024 amendments would have allowed 

them to better understand and compare the drivers of fund performance, the proposed changes 

could reduce competition between registered funds.153  

3. Capital Formation 

To the extent that the potential costs associated with more frequent holdings disclosure 

under the 2024 amendments would disincentivize registered funds from investing in costly 

information production activities, such as performing fundamental research on securities, or 

cause them to forgo certain investment strategies and their associated information production 

activities altogether, the proposed changes would reduce this disincentive, increasing the price 

 
151 See id. at section IV.D.2. 
152  See id. at n. 265. 
153 See id. at text following n. 266. 



92 
 

efficiency of registered fund holdings.154 In turn, more informative prices could lead the issuers 

of the securities held by registered funds to make more efficient capital allocation decisions.155 

In contrast, to the extent that more frequent and consistent information on registered fund 

holdings under the 2024 amendments would have increased price efficiency by improving 

investors’ ability to value securities, ultimately leading to better decisions by issuers on how 

capital is allocated, the proposed revision of Form N-PORT’s publication frequency from 

monthly to quarterly could eliminate any such positive effect on capital formation.156 

E. Reasonable Alternatives 

1. Filing Timeframe 

The Commission is proposing to extend the time registered funds have to file monthly 

Form N-PORT reports with the Commission from 30 days to 45 days. As an alternative, as with 

the 2024 amendments, we considered an even longer filing deadline (e.g., 60 days after each 

month end). A longer filing deadline would provide registered funds with even more time to 

gather, verify, and file information required on Form N-PORT, which could reduce the direct 

costs associated with these activities. In addition, a longer filing deadline could reduce the 

indirect costs associated with filing errors and any subsequent amendments to a registered fund’s 

Form N-PORT reports. At the same time, a longer time to file could reduce the utility of 

information reported on Form N-PORT in exercising the Commission’s oversight 

responsibilities, especially during periods of market stress in which the analysis of potential 

issues and development of any regulatory responses are particularly time sensitive endeavors. 

 
154  See supra notes 118 to 119. 
155  See supra note 108. 
156  See 2024 Adopting Release, supra note 1, at section IV.D.3. 



93 
 

2. Publication of Registered Fund Holdings 

We are proposing to require public disclosure of registered funds’ portfolio holdings for 

the third month of each fiscal quarter with a 60-day delay. As an alternative, we considered 

synchronizing those disclosures across registered funds to occur in the same month of each 

quarter rather than according to each fund’s specific fiscal year schedule, while maintaining the 

60-day delay. While a synchronized quarterly publication requirement would allow investors to 

compare registered fund holdings at the same point in time, funds whose fiscal year-ends are not 

aligned with the synchronized schedule would end up disclosing their holdings more than four 

times per year due to the separate requirement that funds disclose a full schedule of investments 

with their financial statements. This would be more costly for such funds and may expose them 

to a greater risk that external parties may use the more frequent disclosures of the registered 

funds’ portfolio holdings to infer the fund’s proprietary investment strategy or trading intentions 

and use that information in ways that increase costs for the funds and their shareholders, making 

them less competitive than registered funds with fiscal year-ends that are aligned with the 

synchronized schedule. Under this alternative, registered funds could mitigate any risks 

associated with these additional disclosures by adjusting their fiscal year to align with the 

synchronized publication schedule, though they would incur additional costs in doing so. 

As another alternative to the proposed quarterly publication of registered funds’ portfolio 

holdings, we considered retaining the monthly publication frequency from the 2024 

amendments, but with a longer period before publication (e.g., 90 days after month end, or 60 

days after the end of the quarter to which the monthly reports relate). This alternative would 

result in additional time for registered funds to build or dispose of positions before Form N-

PORT reports would provide public information about changes in their portfolio holdings. As a 



94 
 

result, the alternative would reduce the risk that external parties could infer information about a 

registered fund’s trading intentions before the fund has fully established its position in a security 

and may reduce the cost of establishing the position relative to the 2024 amendments. However, 

this alternative would be less effective than the proposed approach in reducing the risk that a 

registered fund’s overall trading strategy is inferred by external parties, as funds’ portfolio 

holdings would continue to be published for every month. 

IV. Paperwork Reduction Act 

A. Introduction 

Certain provisions of the proposed amendments contain “collection of information” 

requirements within the meaning of the Paperwork Reduction Act of 1995 (the “PRA”).157 We 

will submit the proposed collections of information to the Office of Management and Budget 

(“OMB”) for review in accordance with the PRA.158 The proposed amendments would change 

the current collection of information burdens of Form N-PORT under the Investment Company 

Act. 

The title for the existing collection of information is “Rule 30b1-9 and Form N-PORT” 

(OMB control number 3235-0730). An agency may not conduct or sponsor, and a person is not 

required to respond to, a collection of information unless it displays a currently valid OMB 

control number. Each requirement to disclose information constitutes a collection of information 

requirement under the PRA. These collections of information would provide information to the 

Commission and investors. The Commission staff would also use the collection of information in 

 
157  44 U.S.C. 3501–3521. 
158  44 U.S.C. 3507(d); 5 CFR 1320.11. 



95 
 

its examination and oversight programs in identifying patterns and trends across registrants. We 

discuss below the collection of information burdens associated with the proposed amendments. 

B. Form N-PORT 

Form N-PORT requires registered management investment companies (except for money 

market funds and small business investment companies) and ETFs that are organized as unit 

investment trusts to report portfolio holdings information in a structured, XML data language. 

The form is filed electronically using the Commission’s electronic filing system, EDGAR. We 

propose the following amendments to Form N-PORT: 

• Filing timeframe. The proposed amendments to rule 30b1-9 and Form N-PORT 

would require registered funds to file Form N-PORT reports within 45 days after the 

end of the month to which they relate rather than filing monthly reports 30 days after 

the end of each calendar month under the 2024 amendments.  

• Publication frequency. The proposed amendments to Form N-PORT would require 

publication of Form N-PORT reports for the third month of each fiscal quarter with a 

60-day delay, instead of publication of monthly reports with a 60-day delay under the 

2024 amendments.  

• Other proposed amendments. The proposed amendments to Form N-PORT would 

modify certain information collected on portfolio level risk metrics and returns to 

narrow their scope; eliminate certain information collected on registered funds’ 

compliance with names rule-related regulatory requirements, non-derivatives 

instruments’ payoff profiles, convertible bonds, and the reason a single holding has 

multiple liquidity classifications; require funds with ETF share classes to report net 



96 
 

assets and shareholder flows separately for ETF share classes; and require registered 

funds to report additional identifying information, such as tickers. 

The respondents to these collections of information would be management investment 

companies (other than money market funds and small business investment companies) and ETFs 

that are organized as unit investment trusts. We estimate that there are 12,668 such funds 

required to file on Form N-PORT.159 The proposed collections of information are mandatory for 

the identified types of funds. Certain information reported on the form is currently kept 

confidential, and we propose that this would continue to be the case.160  

In the most recent PRA submission for Form N-PORT, the Commission estimated the 

annual aggregate compliance burden to comply with the current collection of information 

requirements in Form N-PORT is 2,000,834 burden hours and an external cost burden estimate 

of $177,742,893.161 While the amendments in the 2024 Adopting Release have not gone into 

effect, the approved PRA estimates reflect those amendments. As a result, the current burden 

estimates reflect the burden hours and external costs associated with a requirement for registered 

funds to file monthly reports with the Commission within 30 days of month end. In connection 

with the 2024 amendments, the Commission did not estimate additional burdens associated with 

changing the publication frequency of Form N-PORT reports.  

We estimate that registered funds prepare and file their reports on Form N-PORT either 

by: (1) licensing a software solution and preparing and filing the reports in house, or (2) retaining 

a service provider to provide data aggregation, validation, and/or filing services as part of the 

 
159  This estimate of the number of registered funds required to file on Form N-PORT is as of Dec. 31, 2024, 

and based on data from filings with the Commission. 
160  See General Instruction F of Form N-PORT; General Instruction F of amended Form N-PORT.  
161  The most recent Form N-PORT PRA submission was approved in 2024 (OMB Control No. 3235-0730). 



97 
 

preparation and filing of reports on behalf of the fund. We estimate that 35% of funds subject to 

the Form N-PORT filing requirements license a software solution and file reports on Form N-

PORT in house, and the remaining 65% retain a service provider to file reports on behalf of the 

fund. 

We are adjusting downward the collection of information burden in connection with the 

proposed requirement to file Form N-PORT reports within 45 days of month end, rather than 

within 30 days of month end. This reduction reflects that burdens of collecting and filing Form 

N-PORT information should be lower because registered funds will have more time to conduct 

these activities and avoid corrective re-submissions of filings. We are not proposing any 

adjustment to the burden estimates in connection with the proposed changes to the publication 

frequency of Form N-PORT reports, as the Commission similarly did not adjust burden estimates 

in 2024, and there is no separate information collection involved with the Commission 

publishing reports that have been filed with us. We are also adjusting downward the collection of 

information burden in connection with the modifications to and elimination of certain items in 

Form N-PORT. This reduction reflects that burdens of collecting and filing Form N-PORT 

information should be lower because registered funds would be required to collect and report less 

overall information.162 

Table 8 below summarizes our initial and ongoing annual burden estimates associated 

with the proposed amendments to Form N-PORT. The following estimates of average burden 

hours and costs are made solely for purposes of the Paperwork Reduction Act. 

  

 
162  This adjustment downward includes consideration of the additional collection of information burden that 

would be imposed by adding information about ETF share classes and by adding additional identifying 
information. 



98 
 

Table 8. Form N-PORT PRA Estimates 

 Initial 
internal 
burden 
hours 

Internal annual 
burden hours1  

Wage 
rate Internal time costs 

Annual external cost 
burden 

PROPOSED AMENDMENTS TO FORM N-PORT 

 

Proposed Amendments to Filing Timeframe and Other Proposed Amendments (Excluding Removal of Names Rule-Related Reporting)  

Funds that license a 
software solution to 
prepare Form N-PORT 

-3 hours -4 hours3 x $4592 -$1,836 -$1,0004 

Number of funds5  × 4,434 funds   × 4,434 funds x 4,434 funds 

Funds that retain the 
services of a third-party 
vendor to prepare Form 
N-PORT 

-3 hours -3 hours6 x $4592 -$1,377 -$2,0007 

Number of funds5  × 8,234 funds   × 8,234 funds x 8,234 funds 

Total new annual 
burden of amendments 
(excluding names rule-

related) 

 -42,438 hours   -$ 19,479,042 -$20,902,000 

Proposed Amendments to Remove Names Rule-Related Reporting7 

Removal of names 
rule-related reporting 

-19 
hours8 

-16 hours8  $406 -$6,496 -$2,260 

Number of funds  x 9,926 funds   x 9,926 funds x 9,926 

Total new annual 
burden of names rule-
related amendments 

 -158,816 hours8   -$64,479,296 -$22,432,760 

Total Estimated Burdens, Including Proposed Amendments 

Current burden 
estimates 

 2,070,316 hours9    $177,742,893 

Revised burden 
estimates 

 1,869,062 hours    $134,408,133 

Certain products and sums do not tie due to rounding. 

Notes: 

1. Includes initial burden estimates annualized over a 3-year period.  

2. The $459 wage rate reflects current estimates of the blended hourly rate for an accountant and auditor ($348), paralegal and legal 
assistant ($285), and attorney ($744) in the securities industry. To calculate the occupational hourly rates used in this release, the 
Commission uses occupational mean hourly wage data from the Occupational Employment and Wage Statistics (OEWS) program of the 
Bureau of Labor Statistics (BLS) for “Securities, Commodity Contracts, and Other Financial Investments and Related Activities” (NAICS 
523). See Occupational Employment and Wage Statistics, U.S. Bureau of Labor Statistics, https://www.bls.gov/oes/; see also Standard 
Occupational Classification, U.S. Bureau of Labor Statistics, https://bls.gov/soc/ (describing occupational classification system used by 
BLS); Exec. Off. of the President, Off. of Mgmt. & Budget, North American Industry Classification System (2022), available at 
https://www.census.gov/naics/reference_files_tools/2022_NAICS_Manual.pdf (describing the industry classification system used by 
BLS and other agencies). The mean hourly wage for each occupation is adjusted for changes in the seasonally adjusted employment 
cost index for private wages and salaries between the data reference period and when the data are released by BLS. See Employment 
Cost Index, U.S. Bureau of Labor Statistics, https://www.bls.gov/eci/. The adjusted mean hourly wage is then multiplied by a factor that 
accounts for nonwage costs borne by employers, such as bonuses, benefits, and overhead. This factor is calculated as an average over 
the 10 most recently available years of data of the ratio of the Bureau of Economic Analysis’s annual gross output data for NAICS 523 
to total annual wages across all occupations for NAICS 523 in the OEWS data. See Gross Output by Industry, U.S. Bureau of Economic 
Analysis, https://www.bea.gov/data/industries/gross-output-by-industry; Occupational Employment and Wage Statistics, U.S. Bureau 
of labor Statistics, https://wwww.bls.gov/oes/. The final product is the occupational hourly rate. See generally Updated Methodology 

https://www.bls.gov/oes/
https://bls.gov/soc/


99 
 

for Calculating Occupational Hourly Rates (Dec. 19, 2025), available at https://www.sec.gov/files/method-occupational-hourly-
rates.pdf. 

3. In the most recent Form N-PORT PRA submission that was approved in 2024 (OMB Control No. 3235-0730), the added initial burden 
was 6 hours and the added ongoing burden was 5 hours. Relative to that PRA submission, our proposed estimates reflect a reduction 
of initial burden of 3 hours, annualized over a 3-year period, and a reduction of ongoing annual burden of 3 hours. As a result, we are 
retaining an estimated ongoing annual burden of 3 hours per year for filing reports within 45 days of month end, while also accounting 
for the reductions in information that funds would be required to report. This burden estimate is a reduction from the 7 annual burden 
hours estimated in the 2024 Adopting Release. 

4. In the most recent Form N-PORT PRA submission that was approved in 2024 (OMB Control No. 3235-0730), the added external cost 
burden was $41,452,000. Our proposed estimates reflect a reduction of external cost of $1,000 for funds that license a software 
solution to prepare Form N-PORT reports and a reduction of external cost of $2,000 for funds that retain the services of a third-party 
vendor to prepare Form N-PORT reports. This burden estimate is a reduction from the $2,000 and $4,000 external cost burden per 
fund, respectively, estimated in the 2024 Adopting Release. 

5. Based on Commission filings, we estimate that there are 12,668 funds that file reports on Form N-PORT. We estimate that 35% of 
these funds (or 4,434) would license a software solution to prepare Form N-PORT while 65% (or 8,234) would rely on a third-party 
vendor. 

6. In the most recent Form N-PORT PRA submission that was approved in 2024 (OMB Control No. 3235-0730), the added initial burden 
was 6 hours and the added ongoing annual burden was 3 hours. Relative to that PRA submission, our proposed estimates reflect a 
reduction of initial burden of 3 hours, annualized over a 3-year period, and a reduction of ongoing annual burden of 2 hours. As a 
result, we are retaining an estimated ongoing annual burden of 2 hours per year for filing reports within 45 days of month end, while 
also accounting for the reductions in information that funds would be required to report. This burden estimate is a reduction from the 5 
annual burden hours estimated in the 2024 Adopting Release. 

7. In the names rule-related PRA submission that was approved in 2023 (OMB Control No. 3235-0730), the added initial burden was 
12 hours and the added ongoing annual burden was 9 hours for 9,926 funds at an internal cost of $406 and external costs of $2,260 
per fund to report the names rule-related information. We are using the same number of funds, burden hours, wage rates, and external 
costs for these purposes because the Commission has not reassessed the burdens of this reporting since the 2023 names rule 
adoption, and funds have not been required to comply with the names rule-related reporting requirements. If we were to update our 
analysis and use larger or smaller numbers than those used in 2023, this would have unintended effects on the overall PRA estimates 
for Form N-PORT. As an example, larger estimates than those used in 2023 would suggest that removal of these items would not only 
remove the burdens associated with reporting these items, but also have a greater effect on reducing the burdens of Form N-PORT 
reporting.  

8. Due to an error in the names rule-related PRA submission that was approved in 2023 (OMB Control No. 3235-0730), there is a 
discrepancy between the PRA submission and the Commission’s Names Rule Adopting Release with respect to the estimated burden 
hours for names rule-related reporting on Form N-PORT. The burden hour figures in this table are consistent with those the Commission 
estimated in the Names Rule Adopting Release and thus correct the typographical error in the PRA submission.  

9. Because of the correction of the error in the names rule-related PRA submission that was approved in 2023 (OMB Control No. 3235-
0730), the current burden estimate in this table does not align with the current burden estimate in the most recent Form N-PORT PRA 
submission approved in 2024 (OMB Control No. 3235-0730), which reflected an annual internal burden hour estimate of 2,000,834. If 
we instead used the annual internal burden hour estimate approved in 2024, this would have the unintended effect of suggesting that 
removal of the names rule-related reporting would not only remove the burdens associated with reporting these items, but also have a 
greater effect on reducing the burdens of Form N-PORT reporting. 

 

C. Request for Comment 

We request comment on whether these estimates are reasonable. Pursuant to 44 U.S.C. 

3506(c)(2)(B), the Commission solicits comments in order to: (1) evaluate whether the proposed 

collection of information is necessary for the proper performance of the functions of the 

Commission, including whether the information will have practical utility; (2) evaluate the 

accuracy of the Commission’s estimate of the burden of the proposed collection of information, 

including the validity of the methodology and assumptions used; (3) determine whether there are 



100 
 

ways to enhance the quality, utility, and clarity of the information to be collected; and (4) 

determine whether there are ways to minimize the burden of the collection of information on 

those who are to respond, including through the use of appropriate automated, electronic, 

mechanical, or other technological collection techniques or other forms of information 

technology. 

Persons wishing to submit comments on the collection of information requirements of the 

proposed amendments should direct them to the OMB Desk Officer for the Securities and 

Exchange Commission, [email protected], and should send a 

copy to Vanessa A. Countryman, Secretary, Securities and Exchange Commission, 100 F Street 

NE, Washington, DC 20549-1090, with reference to File No. S7-2026-05. OMB is required to 

make a decision concerning the collections of information between 30 and 60 days after 

publication of this release; therefore a comment to OMB is best assured of having its full effect if 

OMB receives it within 30 days after publication of this release. Requests for materials 

submitted to OMB by the Commission with regard to these collections of information should be 

in writing, refer to File No. S7-2026-05, and be submitted to the Securities and Exchange 

Commission, Office of FOIA Services, 100 F Street NE, Washington, DC 20549-2736. 

V. Initial Regulatory Flexibility Analysis 

The Commission has prepared the following Initial Regulatory Flexibility Analysis 

(“IRFA”) in accordance with section 3(a) of the Regulatory Flexibility Act (“RFA”).163 It relates 

to the proposed amendments to Form N-PORT. 

 
163  5 U.S.C. 603(a) 

mailto:[email protected]101 
 

A. Reasons for and Objectives of Proposed Actions 

 The Commission is proposing amendments to reporting requirements on Form N-PORT 

that would provide registered funds with fifteen additional days to file reports, restore the 

quarterly publication frequency, and make modifications to the report form. The objectives of the 

proposed amendments to the filing timeframe and publication frequency are to reduce burden 

and the risk of external parties inferring and using information about a registered fund’s 

proprietary investment strategy or trading intentions in ways that increase costs for fund 

shareholders while maintaining timely Commission access to registered funds’ monthly 

portfolio-related information and providing for appropriate public access to portfolio 

information. The Commission is also proposing amendments to Form N-PORT to streamline or 

remove certain items, to modify how registered funds with share classes that operate as ETFs 

report certain information, and to require additional identifying information. The objectives of 

the proposed amendments to items within Form N-PORT are to refine the information registered 

funds provide while maintaining the usability and reliability of Form N-PORT data. Each of 

these objectives is discussed in detail in section II above. 

B. Legal Basis 

The Commission is proposing the rule and form amendments contained in this document 

under the authority set forth in the Investment Company Act, particularly sections 8, 24, 30, and 

38 thereof [15 U.S.C. 80a-1 et seq.]. 

C. Small Entities Subject to the Amendments 

An investment company is a small entity if, together with other investment companies in 

the same group of related investment companies, it has net assets of $50 million or less as of the 



102 
 

end of its most recent fiscal year.164 Commission staff estimates that, as of December 2024, there 

were 30 open-end management investment companies subject to Form N-PORT reporting 

requirements that would be considered small entities; this number includes 4 open-end ETFs.165 

Commission staff also estimates that, as of December 2024, there were 38 closed-end investment 

management companies that would be considered small entities. All of these small entities would 

be subject to the proposed amendments to the filing timeframe and publication frequency. The 

number of small entities that would be affected by the proposed amendments to the reporting 

items within Form N-PORT would generally depend on the portfolio of each small entity.  

D. Projected Reporting, Recordkeeping, and Other Compliance Requirements 

As finalized in the 2024 amendments, Form N-PORT requires open-end and closed-end 

funds, as well as ETFs organized as UITs, to report monthly portfolio holdings information on a 

monthly basis in a structured, XML format within 30 days after month end. Under the 2024 

amendments, each month’s data will be published 60 days after month end. We propose 

amendments to require these funds to file Form N-PORT reports on a monthly basis within 45 

days after month end and to publish reports for only the third month of a fund’s fiscal quarter 60 

days after month end. We also propose additional amendments to certain items and sub-items on 

Form N-PORT. 

We estimate that 68 open-end and closed-end funds are small entities that would be 

required to comply with our proposed amendments to Form N-PORT. The proposed 

amendments are intended to reduce the risk of errors in the reported information and reduce 

 
164  The Commission has a pending proposal addressing the definition under the Investment Company Act of 

small organization and small business for purposes of the Regulatory Flexibility Act. The Commission 
encourages commenters to review the proposal to determine whether it might affect their comments on this 
IRFA. See Small Entity Proposing Release, supra note 81. 

165  While exchange-traded funds organized as unit investment trusts file Form N-PORT, there are no such 
funds that would be considered small entities. 



103 
 

reporting burdens, while continuing to recognize that Form N-PORT information is most 

valuable to the Commission and staff when it reflects reasonably current portfolio holdings and 

related information. The proposed amendments would also reduce the overall burden on small 

entities by providing fifteen additional days to file Form N-PORT compared to the 2024 

amendments and by streamlining or eliminating certain reporting requirements. We discuss the 

specifics of those burden reductions in the Economic Analysis and Paperwork Reduction Act 

sections above. 

E. Duplicative, Overlapping, or Conflicting Federal Rules 

We do not believe that the proposed amendments would duplicate, overlap, or conflict 

with other existing Federal rules. 

F. Significant Alternatives 

The RFA directs the Commission to consider significant alternatives that would 

accomplish our stated objectives, while minimizing any significant economic impact on small 

entities. We considered the following alternatives for small entities in relation to the proposed 

amendments to Form N-PORT to enhance the benefits of the proposal for small entities: (1) 

establishing different requirements that take into account the resources available to small entities; 

(2) exempting small entities from all or part of the requirements; (3) clarifying, consolidating, or 

simplifying requirements under the rules for small entities; and (4) using performance rather than 

design standards. 

The proposed amendments relating to the filing timeframe are designed to reduce the risk 

of errors in the reported information and reduce reporting burdens, while continuing to recognize 

that Form N-PORT information is most valuable to the Commission and staff when it reflects 

reasonably current portfolio holdings and related information. We anticipate registered funds, 



104 
 

including smaller funds, would benefit from these proposed amendments. We considered 

providing registered funds that are small entities with additional time to file their reports on 

Form N-PORT, such as 60 days after month end. This alternative would further reduce reporting 

costs for registered funds that are small entities. However, delays in the receipt of information 

can affect the Commission’s and the staff’s ability to use Form N-PORT information to carry out 

the Commission’s regulatory function for the asset management industry, and the associated 

benefits of these activities for investors, especially during periods of stress in which analysis of 

potential issues and development of any regulatory responses are particularly time sensitive 

endeavors. For instance, further delaying the receipt of information for registered funds that are 

small entities could hinder the Commission staff’s ability to identify efficiently small funds 

affected in a market stress event. Moreover, delaying the receipt of information for registered 

funds that are small entities would reduce the benefits of receiving more timely information from 

other registered funds, as the information available to the staff would necessarily be incomplete 

until small entities filed at a later date.  

We also considered allowing registered funds that are small entities to make less 

frequent, or more delayed, public disclosure of their portfolio holdings on Form N-PORT. 

However, the costs of an increased publication frequency of portfolio holdings generally relate 

more to a fund’s strategy than its size, so such a change may not significantly benefit registered 

funds that are small entities. Moreover, registered funds that are small entities may be at a lower 

risk for certain types of front running. For example, registered funds that are small entities are 

more likely than other funds to have relatively small position sizes, meaning that it may take 

smaller registered funds less time to build or dispose of positions, which reduces the risk of front 

running. Additionally, all registered fund investors, including investors in funds that are small 



105 
 

entities, benefit from reporting requirements that permit them to make investment choices that 

better match their risk tolerances. Thus, the interest of investors would not be served by 

establishing different Form N-PORT publication requirements for registered funds that are small 

entities. 

The amendments to Form N-PORT’s reporting items would overall reduce reporting 

costs, including for registered funds that are small entities. A few of the amendments would 

amend the reporting threshold of a particular item. Registered funds, including small funds, with 

activity below the reporting threshold would not be required to provide the information. We 

considered higher thresholds for funds that are small entities. While this would further reduce 

costs for these funds, it would result in non-standardized information that is less beneficial to the 

Commission and the public. For example, higher thresholds for small entities would make it 

more difficult to understand interest and credit risks of these funds, as they would have higher 

reporting thresholds for portfolio level risk metrics.  

The proposal would add a few reporting requirements for registered funds with ETF 

share classes. This new reporting would introduce minimal burdens for affected funds. Currently, 

no small entities offer ETF share classes. This could change in the future, and thus we considered 

exempting registered funds that are small entities from these new requirements. Such a change 

would create a minimal burden reduction for small entities if they begin to offer ETF share 

classes. However, an exemption from these requirements would reduce the Commission’s and 

investors’ ability to better understand this growing type of fund structure and to monitor the size 

and flows of different registered funds. 



106 
 

With respect to using performance rather than design standards, the proposed 

amendments primarily use design rather than performance standards to promote more consistent 

and uniform standards for all registered funds. 

G. General Request for Comment 

The Commission requests comments regarding this IRFA. We request comments on the 

number of small entities that may be affected by our proposed amendments and whether the 

proposed amendments would have any effects not considered in this analysis. We request that 

commenters describe the nature of any effects on small entities subject to the rules and forms, 

and provide empirical data to support the nature and extent of such effects. We also request 

comment on the proposed compliance burdens and the effect these burdens would have on 

smaller entities. 

VI. Consideration of Impact on the Economy 

For purposes of Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 

1996 (also known as the Congressional Review Act),166 the Commission must seek OMB’s 

determination whether a final regulation constitutes a “major” rule. Under the Act, a rule is 

considered “major” where, if adopted, it results in or is likely to result in: 

• An annual effect on the economy of $100 million or more;  

• A major increase in costs or prices for consumers or individual industries; or 

• Significant adverse effects on competition, investment, or innovation.167 

To help inform OMB’s determination whether any final rule that results from the 

proposal would be a “major rule,” we solicit comment and data on: 

 
166  See 5 U.S.C. chapter 8. 
167  See 5 U.S.C. 804(2) (defining “major rule”). 



107 
 

• The potential effect on the U.S. economy on an annual basis; 

• Any potential increase in costs or prices for consumers or individual industries; 

and 

• Any potential effect on competition, investment, or innovation. 

Commenters are requested to provide empirical data and other factual support for their 

views to the extent possible.  

VII. Other Matters 

This action is an economically significant regulatory action under section 3(f)(1) of 

Executive Order 12866, as amended, and has been reviewed by the Office of Management and 

Budget. This action, if finalized as proposed, is expected to be an Executive Order 14192 

deregulatory action.  

Statutory Authority 

 The Commission is proposing the rule and form amendments contained in this document 

under the authority set forth in the Investment Company Act, particularly sections 8, 24, 30, and 

38 thereof [15 U.S.C. 80a-1 et seq.]. 

List of Subjects in 17 CFR Parts 270 and 274 

Investment companies, Reporting and recordkeeping requirements, Securities. 

Text of Rule Amendments 

For the reasons stated in the preamble, the Commission proposes to amend 17 CFR parts 

270 and 274 as follows: 

PART 270—RULES AND REGULATIONS, INVESTMENT COMPANY ACT OF 1940 

1. The authority citation for part 270 continues to read, in part, as follows:  



108 
 

Authority: 15 U.S.C. 80a-1 et seq., 80a-34(d), 80a-37, 80a-39, 1681w(a)(1), 6801-6809, 

6825, and Pub. L. 111-203, sec. 939A, 124 Stat. 1376 (2010), unless otherwise noted. 

*  *  *  *  * 

2. Amend § 270.30b1-9 by revising it to read as follows: 

§ 270.30b1-9 Monthly report. 

 Each registered management investment company or exchange-traded fund organized as 

a unit investment trust, or series thereof, other than a registered open-end management 

investment company that is regulated as a money market fund under § 270.2a-7 or a small 

business investment company registered on Form N-5 (§§ 239.24 and 274.5 of this chapter), 

must file a monthly report of portfolio holdings on Form N-PORT (§ 274.150 of this chapter), 

current as of the last business day, or last calendar day, of the month. A registered investment 

company that has filed a registration statement with the Commission registering an offering of its 

securities for the first time under the Securities Act of 1933 is relieved of this reporting 

obligation with respect to any reporting period or portion thereof prior to the date on which that 

registration statement becomes effective or is withdrawn. Reports on Form N-PORT must be 

filed with the Commission no later than 45 days after the end of each month. If a registered 

investment company does not file monthly reports within 45 days after the end of each month in 

accordance with the transition period described in Investment Company Act Release No. 35962 

(Feb. 18, 2026), it must maintain in its records the information that is required to be included on 

Form N-PORT no later than 30 days after the end of each month. Such information shall be 

treated as a record under section 31(a)(1) of the Act [15 U.S.C. 80a30(a)(1)] and § 270.31a-1(b) 

subject to the requirements of § 270.31a-2(a)(2). 

§ 270.30b1-9 [Amended] 



109 
 

 3. Effective 18 months after publication of final rules in the Federal Register, further 

amend § 270.30b1-9 by removing the last two sentences. 

PART 274—FORMS PRESCRIBED UNDER THE INVESTMENT COMPANY ACT OF 

1940 

4. The general authority citation for part 274 continues to read, in part, as follows:  

 Authority: 15 U.S.C. 77f, 77g, 77h, 77j, 77s, 78c(b), 78l, 78m, 78n, 78n-1, 78o(d), 80a-

8, 80a-24, 80a-26, 80a-29, and sec. 939A, Pub. L. 111-203, 124 Stat. 1376, unless otherwise 

noted. 

* * * * * 

5. Amend § 274.150 by revising paragraph (a) to read as follows: 

§ 274.150 Form N–PORT, Monthly portfolio holdings report. 

 (a) Except as provided in paragraph (b) of this section, this form shall be used by 

registered management investment companies or exchange-traded funds organized as unit 

investment trusts, or series thereof, to file reports pursuant to § 270.30b1–9 of this chapter no 

later than 45 days after the end of each month.  

* * * * * * 

6. Amend Form N-PORT (referenced in § 274.150) by: 

a. Revising General Instructions A, E, and F; 

b. Redesignating current Item A.3 as Item A.4 and Item A.4 as Item A.5; 

c. Adding new Item A.3; 

d. Revising Items B.1, B.3, B.5, and B.6; 

e. Removing Item B.11; 

f. Revising Item C.2; 



110 
 

g. Removing and reserving Item C.3; and 

h. Revising Item C.7, Item C.9, and Part D. 

Note: Form N-PORT is attached as Appendix A to this document. Form N-PORT will not 

appear in the Code of Federal Regulations.   

By the Commission. 

Dated: February 18, 2026. 

 

 

Vanessa A. Countryman,  

Secretary. 

Note: The following appendix will not appear in the Code of Federal Regulations. 

  



111 
 

Appendix A–Form N-PORT 

FORM N-PORT 

* * * * * 

GENERAL INSTRUCTIONS 

A. Rule as to Use of Form N-PORT  

 Form N-PORT is the reporting form that is to be used for monthly reports of Funds other 

than money market funds and SBICs under section 30(b) of the Act, as required by rule 30b1-9 

under the Act (17 CFR 270.30b1-9). Funds must report information about their portfolios and 

each of their portfolio holdings as of the last business day, or last calendar day, of each month. A 

registered investment company that has filed a registration statement with the Commission 

registering an offering of its securities for the first time under the Securities Act of 1933 is 

relieved of this reporting obligation with respect to any reporting period or portion thereof prior 

to the date on which that registration statement becomes effective or is withdrawn. 

Reports on Form N-PORT must disclose portfolio information as calculated by the fund 

for the reporting period’s ending net asset value (commonly, and as permitted by rule 2a-4, the 

first business day following the trade date). Reports on Form N-PORT for each month must be 

filed with the Commission no later than 45 days after the end of such month. If the due date falls 

on a weekend or holiday, the filing deadline will be the next business day.  

A Fund may file an amendment to a previously filed report at any time, including an 

amendment to correct a mistake or error in a previously filed report. A Fund that files an 

amendment to a previously filed report must provide information in response to all items of 

Form N-PORT, regardless of why the amendment is filed. 

* * * * * 



112 
 

E. Definitions 

References to sections and rules in this Form N-PORT are to the Act, unless otherwise 

indicated.  Terms used in this Form N-PORT have the same meanings as in the Act or related 

rules (including rule 18f-4 solely for Items B.9 and 10 of the Form), unless otherwise indicated.  

As used in this Form N-PORT, the terms set out below have the following meanings:  

“Absolute VaR Test” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Class” means a class of shares issued by a Fund that has more than one class that 

represents interests in the same portfolio of securities under rule 18f-3 [17 CFR 270.18f-3] or 

under an order exempting the Fund from provisions of section 18 of the Act [15 U.S.C. 80a-18]. 

“Controlled Foreign Corporation” has the meaning provided in section 957 of the Internal 

Revenue Code [26 U.S.C. 957]. 

“Derivatives Exposure” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Designated Index” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Designated Reference Portfolio” has the meaning defined in rule 18f-4(a) [17 CFR 

270.18f-4(a)] 

“Exchange-Traded Fund” means an open-end management investment company (or 

Series or Class thereof) or unit investment trust (or series thereof), the shares of which are listed 

and traded on a national securities exchange at market prices, and that has formed and operates 

under an exemptive order under the Act granted by the Commission or in reliance on rule 6c-11 

[17 CFR 270.6c-11].  

“ETF Class” means a Class that is an Exchange-Traded Fund in a Multiple Class Fund.  

“Fund” means the Registrant or a separate Series of the Registrant.  When an item of 

Form N-PORT specifically applies to a Registrant or a Series, those terms will be used.  



113 
 

“Highly Liquid Investment Minimum” has the meaning defined in rule 22e-4(a)(7) [17 CFR 

270.22e-4(a)(7)]. 

“Illiquid Investment” has the meaning defined in rule 22e-4(a)(8) [17 CFR 270.22e-

4(a)(8)].  

“ISIN” means, with respect to any security, the “international securities identification 

number” assigned by a national numbering agency, partner, or substitute agency that is 

coordinated by the Association of National Numbering Agencies.  

“LEI” means, with respect to any company, the “legal entity identifier” as assigned by a 

utility endorsed by the Global LEI Regulatory Oversight Committee or accredited by the Global 

LEI Foundation.   

“Multiple Class Fund” means a Fund that has more than one Class. 

“Registrant” means a management investment company, or an Exchange-Traded Fund 

organized as a unit investment trust, registered under the Act. 

“Relative VaR Test” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Restricted Security” has the meaning defined in rule 144(a)(3) under the Securities Act of 1933 

[17 CFR 230.144(a)(3)]. 

“RSSD ID” means the identifier assigned by the National Information Center of the 

Board of Governors of the Federal Reserve System, if any. 

“Securities Portfolio” has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“Series” means shares offered by a Registrant that represent undivided interests in a 

portfolio of investments and that are preferred over all other series of shares for assets 

specifically allocated to that series in accordance with rule 18f-2(a) [17 CFR 270.18f-2(a)].  



114 
 

“Swap” means either a “security-based swap” or a “swap” as defined in sections 3(a)(68) 

and (69) of the Securities Exchange Act of 1934 [15 U.S.C. 78c(a)(68) and (69)] and any rules, 

regulations, or interpretations of the Commission with respect to such instruments.  

“Value-at-Risk” or VaR has the meaning defined in rule 18f-4(a) [17 CFR 270.18f-4(a)]. 

“VaR Ratio” means the value of the Fund’s portfolio VaR divided by the VaR of the 

Designated Reference Portfolio. 

F. Public Availability 

 Information reported on Form N-PORT for the third month of each Fund’s fiscal quarter 

will be made publicly available 60 days after the end of the Fund’s fiscal quarter. 

 The SEC does not intend to make public the information reported on Form N-PORT for 

the first and second months of each Fund’s fiscal quarter that is identifiable to any particular 

fund or adviser, or any information reported with respect to a Fund’s Highly Liquid Investment 

Minimum (Item B.7), derivatives transactions (Item B.8), Derivatives Exposure for limited 

derivatives users (Item B.9), median daily VaR (Item B.10.a), median VaR Ratio (Item 

B.10.b.iii), VaR backtesting results (Item B.10.c), country of risk and economic exposure (Item 

C.5.b), delta (Items C.11.c.vii or C.11.g.iv), liquidity classification for portfolio investments 

(Item C.7), or miscellaneous securities (Part D), or explanatory notes related to any of those 

topics (Part E) that is identifiable to any particular fund or adviser. However, the SEC may use 

information reported on this Form in its regulatory programs, including examinations, 

investigations, and enforcement actions. 

* * * * * 

Item A.3. Ticker Information 

a. Ticker symbol of Registrant, if any. 



115 
 

b. For each Class of Registrant or Series, as applicable, the:  

i. EDGAR Class identification number;  

ii. Class name; and  

iii. Ticker symbol. 

* * * * * 

Item B.1. Assets and liabilities.  Report amounts in U.S. dollars. 

* * * * *  

d. If the Fund is a Multiple Class Fund with an ETF Class, also provide the ETF Class’s 

ticker symbol and the information required by Item B.1.c separately for the ETF Class. 

* * * * *  

Item B.3. Portfolio level risk metrics.  If the average value of the Fund’s debt securities 

positions for the previous three months, in the aggregate, exceeds 50% of the Fund’s net asset 

value, provide: 

a. Interest Rate Risk (DV100).  Provide the change in value of the portfolio resulting from a 

100 basis point change in interest rates, aggregated across all currencies for which the 

Fund had a value of 1% or more of the Fund’s net asset value, for each of the following 

maturities: 3 month, 1 year, 5 years, 10 years, and 30 years. 

b. Credit Spread Risk (SDV01, CR01 or CS01).  Provide the change in value of the 

portfolio resulting from a 1 basis point change in credit spreads where the shift is applied 

to the option adjusted spread for each of the following maturities:  3 month, 1 year, 5 

years, 10 years, and 30 years. 

For purposes of Item B.3., calculate value as the sum of the absolute values of:  (i) the value 

of each debt security, (ii) the notional value of each swap, including, but not limited to, total 



116 
 

return swaps, interest rate swaps, and credit default swaps, for which the underlying 

reference asset or assets are debt securities or an interest rate; (iii) the notional value of each 

futures contract for which the underlying reference asset or assets are debt securities or an 

interest rate; and (iv) the delta-adjusted notional value of any option for which the underlying 

reference asset is an asset described in clause (i),(ii), or (iii).  Report zero for maturities to 

which the Fund has no exposure.  For exposures that fall between any of the listed maturities 

in (a) and (b), use linear interpolation to approximate exposure to each maturity listed above. 

For exposures outside of the range of maturities listed above, include those exposures in the 

nearest maturity. Report in U.S. dollars.  

* * * * *  

Item B.5. Return information.   

a. Monthly total returns of the Fund for each of the preceding three months.  If the Fund is a 

Multiple Class Fund, report returns for a single representative Class.  Such returns shall 

be calculated in accordance with the methodologies outlined in Item 26(b)(1) of Form N-

1A, Instruction 13 to sub-Item 1 of Item 4 of Form N-2, or Item 26(b)(i) of Form N-3, as 

applicable, except the return calculation should not deduct sales loads and redemption 

fees charged to shareholder accounts. 

b. Class identification number (if any) of the representative Class for which returns are 

reported.   

c. For each of the preceding three months, monthly net realized gain (loss) and net change 

in unrealized appreciation (or depreciation) attributable to derivatives for each of the 

following asset categories:  commodity contracts, credit contracts, equity contracts, 



117 
 

foreign exchange contracts, interest rate contracts, and other contracts.  Report in U.S. 

dollars.  Losses and depreciation shall be reported as negative numbers.  

d. For each of the preceding three months, monthly net realized gain (loss) and net change 

in unrealized appreciation (or depreciation) attributable to investments other than 

derivatives.  Report in U.S. dollars.  Losses and depreciation shall be reported as negative 

numbers.  

Instruction to Item B.5. For a Multiple Class Fund, select the representative Class in the 

same manner as described in Instruction 3(a) to Item 4(b)(2) of Form N-1A. 

Item B.6. Flow information.  Provide the aggregate dollar amounts for sales and 

redemptions/repurchases of Fund shares during each of the preceding three months.  If shares of 

the Fund are held in omnibus accounts, for purposes of calculating the Fund’s sales, 

redemptions, and repurchases, use net sales or redemptions/repurchases from such omnibus 

accounts.  The amounts to be reported under this Item should be after any front-end sales load 

has been deducted and before any deferred or contingent deferred sales load or charge has been 

deducted.  Shares sold shall include shares sold by the Fund to a registered unit investment trust.  

For mergers and other acquisitions, include in the value of shares sold any transaction in which 

the Fund acquired the assets of another investment company or of a personal holding company in 

exchange for its own shares.  For liquidations, include in the value of shares redeemed any 

transaction in which the Fund liquidated all or part of its assets.  Exchanges are defined as the 

redemption or repurchase of shares of one Fund or series and the investment of all or part of the 

proceeds in shares of another Fund or series in the same family of investment companies.   

* * * * * 



118 
 

d. If the Fund is a Multiple Class Fund with an ETF Class, also provide the information 

required by Item B.6.a through B.6.c separately for the ETF Class. 

* * * * * 

Item C.2. Amount of each investment. 

a. Balance.  Indicate whether amount is expressed in number of shares, principal amount, or 

other units.  For derivatives contracts, as applicable, provide the number of contracts. 

b. Currency.  Indicate the currency in which the investment is denominated. 

c. Value.  Report values in U.S. dollars.  If currency of investment is not denominated in 

U.S. dollars, provide the exchange rate used to calculate value. 

d. Percentage value compared to net assets of the Fund. 

Item C.3. [Reserved] 

* * * * * 

Item C.7. Liquidity classification information.  For portfolio investments of open-end 

management investment companies, provide the liquidity classification(s) for each portfolio 

investment among the following categories as specified in rule 22e-4 [17 CFR 270.22e-4]. For 

portfolio investments with multiple liquidity classifications, indicate the percentage amount 

attributable to each classification.  

a.  Highly Liquid Investments  

b. Moderately Liquid Investments  

c. Less Liquid Investments  

d. Illiquid Investments 



119 
 

Instructions to Item C. 7 Funds may choose to indicate the percentage amount of a holding 

attributable to multiple classification categories only in the following circumstances: (1) if 

portions of the position have differing liquidity features that justify treating the portions 

separately; (2) if a fund has multiple sub-advisers with differing liquidity views; or (3) if the 

fund chooses to classify the position through evaluation of how long it would take to 

liquidate the entire position (rather than basing it on the sizes it would reasonably 

anticipated trading). In (1) and (2), a fund would classify using the reasonably anticipated 

trade size for each portion of the position.  

* * * * * 

Item C.9. For debt securities, also provide: 

* * * * * 

f.  For convertible securities, also provide: 

i. Mandatory convertible?  [Y/N] 

ii. Contingent convertible?  [Y/N] 

iii. Description of the reference instrument, including the name of issuer, title of issue, 

and currency in which denominated, as well as CUSIP of reference instrument, ISIN 

(if CUSIP is not available), ticker (if CUSIP and ISIN are not available), or other 

identifier (if CUSIP, ISIN, and ticker are not available).  If other identifier provided, 

indicate the type of identifier used. 

* * * * * 

Part D: Miscellaneous Securities 



120 
 

For reports filed for the last month of each fiscal quarter, report miscellaneous securities, if any, 

using the same Item numbers and reporting the same information that would be reported for each 

investment in Part C if it were not a miscellaneous security.  Information reported in this Item 

will be nonpublic. 

* * * * *